Legal Opinion

Morris Plan Co. v. Commissioner

United States Tax Court

Decided January 27, 1960No. Docket No. 63676Published

Excess Profits Credit -- Borrowed Capital -- Sec. 439(b)(1). -- Certificates issued by a California industrial loan company to raise its working capital held evidence of investments by the registered owners and borrowed capital under section 439(b)(1).

1Opinion of the Court

The Morris Plan Company of California, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Morris Plan Co. v. Commissioner

Docket No. 63676

United States Tax Court

33 T.C. 720; 1960 U.S. Tax Ct. LEXIS 221;

January 27, 1960, Filed

Decision will be entered under Rule 50.

Excess Profits Credit -- Borrowed Capital -- Sec. 439(b)(1). -- Certificates issued by a California industrial loan company to raise its working capital held evidence of investments by the registered owners and borrowed capital under section 439(b)(1).

F. Daniel Frost III, Esq., and John J. Waller, Esq., for the…

2Cases cited9 opinions

  1. Economy Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1945
  2. Economy Savings & Loan Co. v. Commissioner of Int. Rev.Court of Appeals for the Sixth Circuit · 1946
  3. Commissioner of Internal Revenue v. Ames Trust & Sav. BankCourt of Appeals for the Eighth Circuit · 1950
  4. Capital Nat'l Bank v. CommissionerUnited States Tax Court · 1951
  5. Ames Trust & Sav. Bank v. CommissionerUnited States Tax Court · 1949

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