Legal Opinion

Harding Glass Co. v. Commissioner

United States Board of Tax Appeals

Decided February 26, 1929No. Docket No. 19708PublishedCited by 2 opinions

Notes of solvent persons, worth their face amount, received in payment for an equal amount in par value of the capital stock of a West Virginia corporation, are to be included at their face value in computing the invested capital of such corporation.

1Opinion of the Court

*622OPINION.

Phillips :

The parties to this proceeding have stipulated that the amount of depreciation allowable for the years 1920 and 1921 is $23,382.20 and $29,037.39, respectively. The sole remaining question is whether the $250,000 of capital stock issued July 20, 1920, for interest-bearing promissory notes of the samé amount should be included in invested capital for the remainder of that year and for the year 1921.

*623The Revenue Act of 1918, section 326, provides that invested capital for any year means “ (2) Actual cash value of tangible property, other than cash, bona fide paid in for stock…

2Cases cited1 opinion

  1. Pittsburgh, Wheeling & Kentucky R. R. v. ApplegateWest Virginia Supreme Court · 1882

3Cited by2 opinions

  1. Columbus Brick & Tile Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  2. Harding Glass Co. v. CommissionerUnited States Board of Tax Appeals · 1929

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