Prosper Shevenell & Son, Inc. v. Commissioner
United States Tax Court
Petitioner made two nontaxable stock distributions to its stockholders prior to the taxable year. Held, its equity invested capital for excess profits tax purposes under section 718 (a), Internal Revenue Code, should not include the amount of such stock distributions.
1Opinion of the Court
OPINION.
Arnold, Judge:
Respondent determined a deficiency of $176.83 in petitioner’s excess, profits tax liability for the taxable year ended November 30,1D41. The sole issue is whether the sum of $105,000 representing the value of stock dividends issued in prior years should be included in petitioner’s equity invested capital for excess profits tax purposes. Two other errors alleged by the petitioner were withdrawn.
The stipulated facts are adopted as a part of our findings of fact.
The petitioner was incorporated under the laws of Massachusetts on July 1,1918, with its principal place of…
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