Morris Plan Co. v. Commissioner
United States Tax Court
Excess Profits Credit -- Borrowed Capital -- Sec. 439(b)(1). -- Certificates issued by a California industrial loan company to raise its working capital held evidence of investments by the registered owners and borrowed capital under section 439(b)(1).
1Opinion of the Court
OPINION.
Murdock, Judge:
The term thrift certificates involved in the present case are not different in any material respect from those involved in the recent case of Valley Morris Plan, 83 T.C. 572, and for the reasons given there we hold that the petitioner is entitled to include the indebtedness evidenced by its term thrift certificates in the computation of the invested capital credit.
The petitioner in the present case is claiming the right to include all of the indebtedness evidenced by its outstanding certificates in the computation of its invested capital credit. These included not only…
2Cases cited8 opinions
- Economy Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1945
- Economy Savings & Loan Co. v. Commissioner of Int. Rev.Court of Appeals for the Sixth Circuit · 1946
- Commissioner of Internal Revenue v. Ames Trust & Sav. BankCourt of Appeals for the Eighth Circuit · 1950
- Capital Nat'l Bank v. CommissionerUnited States Tax Court · 1951
- Cross v. CommissionerUnited States Tax Court · 1984
3 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- United States v. City Loan and Savings CompanyCourt of Appeals for the Sixth Circuit · 1961
- Morris Plan Co. v. CommissionerUnited States Tax Court · 1960