Landesman-Hirschheimer Co. v. Commissioner of Int. Rev.

HICKENLOOPER, Circuit Judge.

The two questions hero presented are whether, in the computation of excess prof its taxes for the year 1919, the Commissioner and the Board should have included in the petitioner’s invested capital (1) an item amounting to $25,244.79, carried as a reserve for cash discounts at the beginning of the year 1919, and (2) an item amounting to not less than $81,250, representing the value of intangible property, namely, good will paid in to the petitioner upon its incorporation in 1896, in consideration of stock issued to members of the partnership to whose business…