Sunshine Cloak & Suit Co. v. Commissioner
United States Board of Tax Appeals
Where the principal stockholder of a close corporation, pursuant to an intention to make a contribution to corporate surplus, instructed his bookkeeper to transfer a portion of the sum credited to his personal account to such surplus, and such order was executed, held, the amount so transferred was allowable as invested capital.
1Opinion of the Court
*542OPINION.
Siei'icin :
The petitioner renews his motion for judgment on the ground that the statute of limitations interposes a bar to the deficiency asserted in view of the numerous decisions involving questions of the statute of limitations since our decision, Sunshine Cloak & Suit Co., 10 B. T. A. 971, denying that motion. Petitioner cites and relies on Joy Floral Co. v. Commissioner, 29 Fed. (2d) 865. We do not think that decision in point. Nor have we been able to find any other decision in conflict with the result of our former holding on the point. The motion is again denied,
*543Turning to the…
2Cited by1 opinion
- Sunshine Cloak & Suit Co. v. CommissionerUnited States Board of Tax Appeals · 1929