Legal Opinion

Mossberg Pressed Steel Corp. v. Commissioner

United States Board of Tax Appeals

Decided January 11, 1928No. Docket No. 8757Published

1. Payments on stock subscriptions may be included in invested capital from the time paid in. 2. Petitioner is not entitled to include in invested capital subscriptions to capital stock until paid. 3. Amount allowable as a deduction on account of the exhaustion of a patent determined. 4. The patent can not be included in invested capital at a value in excess of the cost to the previous owner under section 331 of the Revenue Act of 1918. 5. The evidence is insufficient to…

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1. Payments on stock subscriptions may be included in invested capital from the time paid in. 2. Petitioner is not entitled to include in invested capital subscriptions to capital stock until paid. 3. Amount allowable as a deduction on account of the exhaustion of a patent determined. 4. The patent can not be included in invested capital at a value in excess of the cost to the previous owner under section 331 of the Revenue Act of 1918. 5. The evidence is insufficient to show that certain parts of expenditures originally estimated as overhead expense applicable to the manufacture of tools and…

1Opinion of the Court

MOSSBERG PRESSED STEEL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Mossberg Pressed Steel Corp. v. Commissioner

Docket No. 8757.

United States Board of Tax Appeals

9 B.T.A. 1161; 1928 BTA LEXIS 4287;

January 11, 1928, Promulgated

1. Payments on stock subscriptions may be included in invested capital from the time paid in.

2. Petitioner is not entitled to include in invested capital subscriptions to capital stock until paid.

3. Amount allowable as a deduction on account of the exhaustion of a patent determined.

4. The patent can not be included in invested capital at a…

2Cases cited3 opinions

  1. Central Consumers Wine & Liquor Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  2. Forge Coal Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  3. Mossberg Pressed Steel Corp. v. CommissionerUnited States Board of Tax Appeals · 1928

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