A. Harris & Co. v. Commissioner
United States Board of Tax Appeals
1. Amounts paid by the petitioner in its fiscal years ended January 31, 1920, 1921, and 1922, to former creditors whose claims had been discharged by composition in 1915, held not to be ordinary and necessary expenses of its business, nor deductible from the income of those years. 2. Interest-bearing promissory notes of solvent and responsible makers, actually and bona fide paid in for stock of a Texas corporation, constitute invested capital of such corporation at the time…
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1. Amounts paid by the petitioner in its fiscal years ended January 31, 1920, 1921, and 1922, to former creditors whose claims had been discharged by composition in 1915, held not to be ordinary and necessary expenses of its business, nor deductible from the income of those years. 2. Interest-bearing promissory notes of solvent and responsible makers, actually and bona fide paid in for stock of a Texas corporation, constitute invested capital of such corporation at the time paid in to the extent of their actual fair market value. 3. Where a tax return for the fiscal year ended January 31,…
1Opinion of the Court
*709OPINION.
Love :
The fourth and fifth issues have been settled by stipulation and accordingly we find for the petitioner: (a) that its net income for the fiscal year ended January 31, 1921, as determined by the respondent, shall be decreased in the amount of $1,812.99 representing depreciation on a “ balconade ” acquired by the petitioner on May 1, 1920, at a cost of $24,173.25. The rate of depreciation shall be 10 per cent per annum, and the period of depreciation is nine months; (b) that its invested capital at February 1, 1920, shall be. increased in the amount of $22,500, representing a…
2Cited by7 opinions
- Roussel v. CommissionerUnited States Tax Court · 1961
- Brenner v. CommissionerUnited States Tax Court · 1974
- A. Harris & Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Brenner v. CommissionerUnited States Tax Court · 1974
- Holman v. CommissionerUnited States Tax Court · 1973
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