Lansdale Structural Steel & Machine Co. v. Commissioner
United States Tax Court
1. Property transferred to petitioner as paid-in surplus by its two stockholders in 1933, subject to a purchase money mortgage which petitioner assumed, held includible in equity invested capital under section 718 (a) at its cost to the transferors less the amount of the purchase money mortgage, which was included in borrowed invested capital under section 719. 2. Alleged error in respondent's refusal to make allowance for post-war refund credits in computing invested…
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1. Property transferred to petitioner as paid-in surplus by its two stockholders in 1933, subject to a purchase money mortgage which petitioner assumed, held includible in equity invested capital under section 718 (a) at its cost to the transferors less the amount of the purchase money mortgage, which was included in borrowed invested capital under section 719. 2. Alleged error in respondent's refusal to make allowance for post-war refund credits in computing invested capital, held, not shown on the evidence of record.
1Opinion of the Court
Lansdale Structural Steel & Machine Co., Petitioner, v. Commissioner of Internal Revenue, Respondent
Lansdale Structural Steel & Machine Co. v. Commissioner
Docket No. 10997
United States Tax Court
14 T.C. 1428; 1950 U.S. Tax Ct. LEXIS 142;
June 30, 1950, Promulgated
Decision will be entered for the respondent.
1. Property transferred to petitioner as paid-in surplus by its two stockholders in 1933, subject to a purchase money mortgage which petitioner assumed, held includible in equity invested capital under section 718 (a) at its cost to the transferors less the amount of the purchase money…
2Cases cited5 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Willcuts v. Milton Dairy Co.Supreme Court of the United States · 1927
- Altschul's, Inc. v. CommissionerUnited States Tax Court · 1947
- Lansdale Structural Steel & Machine Co. v. CommissionerUnited States Tax Court · 1950