Cleveland Graphite Bronze Co. v. Comm'r
United States Tax Court
1. Taxpayer entered into an agreement with two underwriters covering the purchase by them of its 30,000 shares of newly authorized preferred stock at $ 100 per share, the underwriters to be paid $ 3.50 per share for their services.
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1. Taxpayer entered into an agreement with two underwriters covering the purchase by them of its 30,000 shares of newly authorized preferred stock at $ 100 per share, the underwriters to be paid $ 3.50 per share for their services. Although a public offering of such shares at $ 100 per share was made, the amount of $ 2,895,000, and not $ 3,000,000, is the amount of "daily capital additions," as defined in section 713 (g) (3), I. R. C., for the purpose of computing the excess profits credit based on income, there being no evidence that the stock was actually sold to the public and certificates…
1Opinion of the Court
The Cleveland Graphite Bronze Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Cleveland Graphite Bronze Co. v. Comm'r
Docket No. 9030
United States Tax Court
10 T.C. 974; 1948 U.S. Tax Ct. LEXIS 177; 77 U.S.P.Q. (BNA) 548;
May 27, 1948, Promulgated
Decision will be entered under Rule 50.
1. Taxpayer entered into an agreement with two underwriters covering the purchase by them of its 30,000 shares of newly authorized preferred stock at $ 100 per share, the underwriters to be paid $ 3.50 per share for their services. Although a public offering of such shares at $ 100 per share was…
2Cases cited7 opinions
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- United States v. General Electric Co.Supreme Court of the United States · 1926
- Myers v. Comm'rUnited States Tax Court · 1946
- International Harvester Co. v. Wisconsin Department of TaxationSupreme Court of the United States · 1944
- Wisconsin Gas & Electric Co. v. United StatesSupreme Court of the United States · 1944
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