Stern Bros. & Co. v. Commissioner
United States Tax Court
1. Petitioner, a dealer and broker in securities, carried all securities in inventory prior to March 20, 1943, whether they were owned by it and held for sale to customers, owned by it and held for investment, or simply in its possession as agent for its customers. On March 20, 1943, petitioner established a separate investment account. Certain securities then owned by petitioner were transferred to the investment account on that date.
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1. Petitioner, a dealer and broker in securities, carried all securities in inventory prior to March 20, 1943, whether they were owned by it and held for sale to customers, owned by it and held for investment, or simply in its possession as agent for its customers. On March 20, 1943, petitioner established a separate investment account. Certain securities then owned by petitioner were transferred to the investment account on that date. Certain securities also owned by petitioner prior to March 20, 1943, were transferred to the investment account after that date during the taxable years.…
1Opinion of the Court
OPINION.
Hill, Judge:
The first question for our determination arises from two contentions made by petitioner concerning the computation of its excess profits net income for the taxable years 1942 through 1945. Petitioner, which computed its excess profits credit based on invested capital, claims first that dividends received on certain of its securities in each of these years should be allowed as a credit in computing its excess profits net income for that year. Furthermore it claims that gains realized from sales and liquidating dividends of certain of its securities in each of these years…
2Cases cited9 opinions
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3Cited by83 opinions
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- Harold S. Divine and Rita K. Divine v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
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