Brown Shoe Co. v. Commissioner

This proceeding seeks redetermination of petitioner’s excess profits tax, computed by the invested capital method, for the fiscal years ended 1942 and 1943. The issues arise from the payment of cash and the transfer of other property to petitioner by certain community groups as an inducement to the location or expansion of petitioner’s factory operations in the communities. Petitioner claimed, and the Commissioner disallowed, (1) a deduction from gross income for depreciation on the property contributed and on the full cost of property acquired in part with contributed cash or equivalent…