Wells Bros. Co. v. Commissioner
United States Board of Tax Appeals
1. Wells Brothers Co. of Illinois and Wells Brothers Construction Co. were not affiliated during the year 1917; they were affiliated during the years 1918 and 1920. 2. Wells Brothers Construction Co. is not entitled to include in invested capital for 1917, 1918, and 1920, the value of certain building contracts and certain contracts for the services of its principal stockholders and officers which it claims it acquired in exchange for shares of its capital stock. 3.…
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1. Wells Brothers Co. of Illinois and Wells Brothers Construction Co. were not affiliated during the year 1917; they were affiliated during the years 1918 and 1920. 2. Wells Brothers Construction Co. is not entitled to include in invested capital for 1917, 1918, and 1920, the value of certain building contracts and certain contracts for the services of its principal stockholders and officers which it claims it acquired in exchange for shares of its capital stock. 3. Assessment and collection of the additional tax for the years 1917 and 1918 involved herein are not barred by the statute of…
1Opinion of the Court
*88OPINION.
Marquette:
These proceedings present for decision four questions which will be discussed in the following order: (1) Are as-' sessment and collection of the additional tax asserted by the re-pondent for the years 1917 and 1918 barred by the statute of limitations? (2) Were the petitioners affiliated during the years 1917, 1918, and 1920? (3) and (4) What amount, if any, is the Maine Company entitled to include in its invested capital on account of the contracts and services which it claims it.acquired from the Wells in consideration of the issuance of its capital stock ? Other issues…
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