Consolidated Goldacres Co. v. Commissioner
United States Tax Court
Petitioner, a Nevada corporation, entered into contracts for erection of mining machinery and plant. Title was retained by the seller until payment, in general dependent upon the amount of ore processed. Held, the contracts did not comprise a "note" or "mortgage" within the intendment of section 719 (a) (1), Internal Revenue Code, as to definition of borrowed invested capital.
1Opinion of the Court
Consolidated Goldacres Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Consolidated Goldacres Co. v. Commissioner
Docket No. 9248
United States Tax Court
8 T.C. 87; 1947 U.S. Tax Ct. LEXIS 313;
January 21, 1947, Promulgated
Decision will be entered for the respondent.
Petitioner, a Nevada corporation, entered into contracts for erection of mining machinery and plant. Title was retained by the seller until payment, in general dependent upon the amount of ore processed. Held, the contracts did not comprise a "note" or "mortgage" within the intendment of section 719 (a) (1),…
2Cases cited8 opinions
- Economy Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1945
- Journal Publishing Co. v. CommissionerUnited States Tax Court · 1944
- Studebaker Bros. Co. of Utah v. WitcherNevada Supreme Court · 1921
- Faisst v. WaldoSupreme Court of Arkansas · 1893
- Consolidated Goldacres Co. v. CommissionerUnited States Tax Court · 1947
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