Legal Opinion

Tri-State Realty Co. v. Commissioner

United States Tax Court

Decided February 14, 1949No. Docket No. 17256Published

Upon the facts, held, the credit balances of an open account in petitioner's accounts payable ledger did not constitute equity invested capital within the meaning of section 718 (a) of the Internal Revenue Code prior to April 18, 1942.

1Opinion of the Court

Tri-State Realty Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Tri-State Realty Co. v. Commissioner

Docket No. 17256

United States Tax Court

12 T.C. 192; 1949 U.S. Tax Ct. LEXIS 276;

February 14, 1949, Promulgated

Decision will be entered under Rule 50.

Upon the facts, held, the credit balances of an open account in petitioner's accounts payable ledger did not constitute equity invested capital within the meaning of section 718 (a) of the Internal Revenue Code prior to April 18, 1942.

Robert A. Littleton, Esq., for the petitioner.

F. S. Gettle, Esq., for the respondent.

Hill,…

2Cases cited2 opinions

  1. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  2. Tri-State Realty Co. v. CommissionerUnited States Tax Court · 1949

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