Legal Opinion

Affiliated Capital Corp. v. Commissioner

United States Tax Court

Decided May 4, 1987No. Docket No. 38021-84Published

In 1970, A incurred costs for the preparation and filing of a registration statement and prospectus with the Securities and Exchange Commission (SEC) for a public offering of 525,000 units of securities. Each unit consisted of 2 shares of common stock and one warrant for the purchase of a share of common stock at a stated or mathematically calculable price.

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In 1970, A incurred costs for the preparation and filing of a registration statement and prospectus with the Securities and Exchange Commission (SEC) for a public offering of 525,000 units of securities. Each unit consisted of 2 shares of common stock and one warrant for the purchase of a share of common stock at a stated or mathematically calculable price. In 1972 and 1975, A incurred additional costs for the preparation and filing with the SEC of post-effective amendments updating the registration statement and prospectus for the warrants. Held, A's costs in preparing and filing the…

1Opinion of the Court

Affiliated Capital Corporation and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent

Affiliated Capital Corp. v. Commissioner

Docket No. 38021-84

United States Tax Court

88 T.C. 1157; 1987 U.S. Tax Ct. LEXIS 65; 88 T.C. No. 65;

May 4, 1987. May 4, 1987, Filed

Decision will be entered under Rule 155.

In 1970, A incurred costs for the preparation and filing of a registration statement and prospectus with the Securities and Exchange Commission (SEC) for a public offering of 525,000 units of securities. Each unit consisted of 2 shares of common stock and one warrant for the…

2Cases cited23 opinions

  1. Securities and Exchange Commission v. Manor Nursing Centers, Inc.Court of Appeals for the Second Circuit · 1972
  2. General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
  3. Davis v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1945
  4. Simmons Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1929
  5. Securities & Exchange Commission v. Bangor Punta Corp.District Court, S.D. New York · 1971

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