Conrad & Co. v. Commissioner
United States Board of Tax Appeals
1. Where a corporation, after March 3, 1917, used a part of its assets to acquire from its stockholders property which such stockholders acquired without cost, section 331 of the Revenue Acts of 1918 and 1921 prohibits the inclusion in invested capital of any value for such assets. 2. In such circumstances invested capital is properly computed by reducing the amount as computed under section 326 by the amount paid for such assets. 3. Special assessment granted.
1Opinion of the Court
CONRAD & CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Conrad & Co. v. Commissioner
Docket Nos. 10042, 18293, 19582.
United States Board of Tax Appeals
13 B.T.A. 1332; 1928 BTA LEXIS 3064;
October 31, 1928, Promulgated
1. Where a corporation, after March 3, 1917, used a part of its assets to acquire from its stockholders property which such stockholders acquired without cost, section 331 of the Revenue Acts of 1918 and 1921 prohibits the inclusion in invested capital of any value for such assets.
2. In such circumstances invested capital is properly computed by reducing the…
2Cases cited2 opinions
- Heirs of Searcy v. ReardonCourt of Appeals of Kentucky · 1816
- Conrad & Co. v. CommissionerUnited States Board of Tax Appeals · 1928