O'Connor v. Comm'r
United States Tax Court
1. During 1945 and 1946, three journal entries were made on petitioners' books indicating an additional contribution to capital by petitioner, in the form of materials and supplies, amounting to $25,104.96. Respondent determined that no additional contribution to capital had been made, and that the materials and supplies in question had been left over from various construction jobs to which they had previously been charged as an expense.
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1. During 1945 and 1946, three journal entries were made on petitioners' books indicating an additional contribution to capital by petitioner, in the form of materials and supplies, amounting to $25,104.96. Respondent determined that no additional contribution to capital had been made, and that the materials and supplies in question had been left over from various construction jobs to which they had previously been charged as an expense. The evidence does not substantiate petitioners' contention that the materials and supplies had been purchased and accumulated prior to the organization of…
1Opinion of the Court
J. D. O'Connor and Blanche J. O'Connor v. Commissioner.
O'Connor v. Comm'r
Docket Nos. 36461, 36462.
United States Tax Court
T.C. Memo 1954-90; 1954 Tax Ct. Memo LEXIS 161; 13 T.C.M. (CCH) 623; T.C.M. (RIA) 54195;
June 30, 1954, Filed
1. During 1945 and 1946, three journal entries were made on petitioners' books indicating an additional contribution to capital by petitioner, in the form of materials and supplies, amounting to $25,104.96. Respondent determined that no additional contribution to capital had been made, and that the materials and supplies in question had been left over from various…
2Cases cited7 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Frank v. CommissionerUnited States Tax Court · 1953
- C. P. Ford & Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Walter H. Goodrich & Co. v. CommissionerUnited States Board of Tax Appeals · 1939
- H & H Drilling Co. v. CommissionerUnited States Tax Court · 1950
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