Harding Glass Co. v. Commissioner
United States Board of Tax Appeals
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
- Pittsburgh, Wheeling & Kentucky R. R. v. ApplegateWest Virginia Supreme Court · 1882
3Cited by2 opinions
- Columbus Brick & Tile Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Harding Glass Co. v. CommissionerUnited States Board of Tax Appeals · 1929