Legal Opinion

Palomar Laundry v. Commissioner

United States Tax Court

Decided December 9, 1946No. Docket No. 5911PublishedCited by 18 opinions

The petitioner was organized as a corporation in 1925. Incident to its organization petitioner entered into an agreement with a stockbroker whereby the broker agreed to obtain subscriptions for 1,600 shares of petitioner's preferred stock at its par value of $ 100 per share and deposit the selling price of $ 160,000 in escrow.

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The petitioner was organized as a corporation in 1925. Incident to its organization petitioner entered into an agreement with a stockbroker whereby the broker agreed to obtain subscriptions for 1,600 shares of petitioner's preferred stock at its par value of $ 100 per share and deposit the selling price of $ 160,000 in escrow. In consideration for such services petitioner agreed to issue to the broker, and did issue, as a commission, 400 shares of its preferred stock having a par value of $ 40,000. Held, that the fair market value of these shares of stock is not includible in petitioner's…

1Opinion of the Court

OPINION.

Black, Judge:

Respondent determined a deficiency in declared value excess profits tax for the year 1941 in the amount of $14.88, and a deficiency in excess profits tax for the years 1941 and 1942 in the respective amounts of $587.63 and $2,889.62. Only the amounts of excess profits tax for the years 1941 and 1942 are in controversy. The deficiencies are due to several adjustments to petitioner’s invested capital for those yeax-s. Petitioner, by appropriate assignments of error, contests only an adjustment of $40,000 for each of these years. In a statement attached to the deficiency…

2Cases cited1 opinion

  1. LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921

3Cited by18 opinions

  1. Difco Laboratories, Inc. v. CommissionerUnited States Tax Court · 1948
  2. Bard-Parker Co. v. CommissionerUnited States Tax Court · 1952
  3. American Business Credit Corp. v. CommissionerUnited States Tax Court · 1947
  4. Warner Co. v. CommissionerUnited States Tax Court · 1948
  5. Western Maryland Railway Company v. United StatesDistrict Court, D. Maryland · 1955

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