Montgomery Bros. & Co. v. Commissioner

*259OPINION.

Trammell:

The facts may be briefly summarized. In 1899 the taxpayer acquired for stock the assets of a business conducted by a partnership. In 1907, for the first time, a detailed appraisal of the taxpayer’s plant and equipment was made by an appraisal company. This appraisal placed a value on the assets which was $84,-062.85 more than the value at which they were carried on the books of the taxpayer. Early in 1909 the taxpayer added to its property and surplus accounts the excess of the appraised value of its assets over the book value, less the amount spent for equipment in 1907 and…