Pacific Affiliate, Inc. v. Commissioner
United States Tax Court
1. Items includible in petitioner's borrowed invested capital, determined. 2. Status of certain securities held and sold by petitioner during taxable years, determined. 3. Period determined over which the premium paid for certain Federal Land Bank bonds purchased and sold in 1943 is amortizable. 4. Whether or not certain dividends received during taxable years are excluded from petitioner's excess profits net income, determined. 5. Contracts to purchase or to sell certain…
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1. Items includible in petitioner's borrowed invested capital, determined. 2. Status of certain securities held and sold by petitioner during taxable years, determined. 3. Period determined over which the premium paid for certain Federal Land Bank bonds purchased and sold in 1943 is amortizable. 4. Whether or not certain dividends received during taxable years are excluded from petitioner's excess profits net income, determined. 5. Contracts to purchase or to sell certain corporate securities when, as and if issued, held, properly recognizable as individual assets on a "gross basis" in…
1Opinion of the Court
Pacific Affiliate, Inc., a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Pacific Affiliate, Inc. v. Commissioner
Docket No. 12836
United States Tax Court
18 T.C. 1175; 1952 U.S. Tax Ct. LEXIS 79;
September 30, 1952, Promulgated
Decision will be entered under Rule 50.
1. Items includible in petitioner's borrowed invested capital, determined.
2. Status of certain securities held and sold by petitioner during taxable years, determined.
3. Period determined over which the premium paid for certain Federal Land Bank bonds purchased and sold in 1943 is amortizable.
4. Whether or not…
Also in this document: Dissent.
2Cases cited14 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Stern Bros. & Co. v. CommissionerUnited States Tax Court · 1951
- Wood v. CommissionerUnited States Tax Court · 1951
- Hart-Bartlett-Sturtevant Grain Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Brewster Shirt Corp. v. CommissionerCourt of Appeals for the Second Circuit · 1947
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