Grand Rapids Dry Goods Co. v. Commissioner
United States Board of Tax Appeals
CONSOLIDATED INVESTED CAPITAL. - Company B was organized in 1912, with a paid-in capital of $60,000. It operated at a loss until August 1, 1919, when its stockholders sold all of their stock to Company A for $15,000 cash. Company B paid no dividends prior to December 31, 1919. Held, that Company B should be included in the consolidated invested capital for the year 1919 at $45,000.
1Opinion of the Court
OPINION.
Green :
When the Grand Rapids Dry Goods Co., on August 1, 1919, purchased the stock of the Corl-Knot Realty Co., these two corporations became affiliated within the meaning of section 240 of the Revenue Act of 1918. Under the provisions of subdivision (a) of that section, corporations are required to make a consolidated return of net income and invested capital. Section 326 of the same Act *697prescribes the items which may be included in invested capital. The material parts of that section are as follows:(a) That as used in this title the term “invested capital” for any year means (except…
2Cases cited2 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Willcuts v. Milton Dairy Co.Supreme Court of the United States · 1927
3Cited by3 opinions
- Albert Lea Packing Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Golden Cycle Corp. v. CommissionerUnited States Board of Tax Appeals · 1929
- Grand Rapids Dry Goods Co. v. CommissionerUnited States Board of Tax Appeals · 1928