Reynolds Spring Co. v. Commissioner
United States Tax Court
Prior to the taxable periods involved, petitioner distributed to its stockholders property in kind not out of earnings and profits. Held, in computing petitioner's excess profits tax credit, its basis for determining the amount by which its equity invested capital is to be reduced under section 718 (b) (1) of the Internal Revenue Code is the basis of the property at the time of distribution, which in this case is the cost of acquisition.
1Opinion of the Court
Reynolds Spring Company, a Delaware Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Reynolds Spring Co. v. Commissioner
Docket No. 16345
United States Tax Court
12 T.C. 110; 1949 U.S. Tax Ct. LEXIS 287;
January 31, 1949, Promulgated
Decision will be entered for the respondent.
Prior to the taxable periods involved, petitioner distributed to its stockholders property in kind not out of earnings and profits. Held, in computing petitioner's excess profits tax credit, its basis for determining the amount by which its equity invested capital is to be reduced under section 718 (b)…
2Cases cited3 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- R. D. Merrill Co. v. CommissionerUnited States Tax Court · 1945
- Reynolds Spring Co. v. CommissionerUnited States Tax Court · 1949