Simmons Co. v. Commissioner
United States Board of Tax Appeals
1. The value of patents for the purpose of depreciation determined. 2. A commission paid for the sale of a corporation's own stock can never serve to increase invested capital, but may reduce invested capital where the previous invested capital included earned surplus or undivided profits. 3. The Revenue Act of 1918 makes no provision for the deduction from income of the amount of the commission paid by a corporation for the sale of its own capital stock.
1Opinion of the Court
SIMMONS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Simmons Co. v. Commissioner
Docket No. 1927.
United States Board of Tax Appeals
8 B.T.A. 631; 1927 BTA LEXIS 2836;
October 8, 1927, Promulgated
1. The value of patents for the purpose of depreciation determined.
2. A commission paid for the sale of a corporation's own stock can never serve to increase invested capital, but may reduce invested capital where the previous invested capital included earned surplus or undivided profits.
3. The Revenue Act of 1918 makes no provision for the deduction from income of the amount of…
2Cases cited19 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Emerson Electric Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Farmers Deposit Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1926
- Simmons Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Simmons & Hammond Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1925
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