Legal Opinion

Brann & Stuart Co. v. Commissioner

United States Tax Court

Decided October 9, 1947No. Docket No. 12675Published

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

  1. Brann & Stuart Co. v. CommissionerUnited States Tax Court · 1947

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