Brann & Stuart Co. v. Commissioner
United States Tax Court
Excess Profits Tax -- Credit Based upon Invested Capital -- Borrowed Capital -- Section 719 (a). -- A taxpayer has borrowed invested capital within the meaning of section 719 (a) where a bank advances money to it on its note for the purpose of financing work under a Government war contract, even though the taxpayer assigns to the bank its right to receive moneys from the Government under the contract.
1Opinion of the Court
The Brann & Stuart Co., Petitioner, v. Commissioner of Internal Revenue, Respondent
Brann & Stuart Co. v. Commissioner
Docket No. 12675
United States Tax Court
9 T.C. 614; 1947 U.S. Tax Ct. LEXIS 69;
October 9, 1947, Promulgated
Decision will be entered under Rule 50.
Excess Profits Tax -- Credit Based upon Invested Capital -- Borrowed Capital -- Section 719 (a). -- A taxpayer has borrowed invested capital within the meaning of section 719 (a) where a bank advances money to it on its note for the purpose of financing work under a Government war contract, even though the taxpayer assigns to the bank…
2Cases cited1 opinion
- Brann & Stuart Co. v. CommissionerUnited States Tax Court · 1947