Commercial Credit Co. v. Tait

SOPER, District Judge.

The Commercial Credit Company, a Delaware corporation, on January 21, 1924, issued 48,000 additional shares of common stock, without par value, each share thereof having an actual value of $22.50. One hundred and thirty-two certificates of stock were issued in varying amounts. The company paid as an issue tax, pursuant to title 11, § 1107, sched*863ule A-2, of the Revenue Act of 1921 (42 Stat. 227, 301, 303 [Comp. St. Ann. Supp. 1923, § 6318p]), the sum of $542.38, but the government demanded an additional tax on said issue of $419.62, making a total tax of $962. The company…