La Salle Nat'l Bank v. Commissioner
United States Tax Court
1. Excess Profits Tax -- Credit Based upon Invested Capital -- Borrowed Capital -- Deposits by State Treasurer -- Sec. 719 (a) (1). -- Deposits by the State of Illinois did not constitute borrowed capital within the meaning of section 719 (a) (1). Commissioner v. Ames Trust & Savings Bank, 185 F. 2d 47, reversing 12 T. C. 770; National Bank of Commerce, 16 T. C. 769; and Capital National Bank of Sacramento, 16 T. C. 1202, followed. 2. Excess Profits Tax -- Credit Based upon…
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1. Excess Profits Tax -- Credit Based upon Invested Capital -- Borrowed Capital -- Deposits by State Treasurer -- Sec. 719 (a) (1). -- Deposits by the State of Illinois did not constitute borrowed capital within the meaning of section 719 (a) (1). Commissioner v. Ames Trust & Savings Bank, 185 F. 2d 47, reversing 12 T. C. 770; National Bank of Commerce, 16 T. C. 769; and Capital National Bank of Sacramento, 16 T. C. 1202, followed. 2. Excess Profits Tax -- Credit Based upon Invested Capital -- Borrowed Capital -- Cashier's Checks -- Sec. 719 (a) (1). -- Outstanding cashier's checks and bank…
1Opinion of the Court
OPINION.
' Murdock, Judge:
’The petitioner used and is entitled to use an excess profits credit based upon invested capital as prescribed by section 714 of the Internal Revenue Code for the years 1943 and 1945 and is entitled to carry its unused excess profits credit for 1943 over to 1945 pursuant to section 710 of the Internal Revenue Code. The only issues are whether deposits by the State of Illinois, outstanding cashier’s checks and bank money orders, and amounts due on purchase of Government securities constituted borrowed capital within the meaning of section 719 (a) (1) in computing the…
2Cases cited7 opinions
- Hart-Bartlett-Sturtevant Grain Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Commissioner of Internal Revenue v. Ames Trust & Sav. BankCourt of Appeals for the Eighth Circuit · 1950
- Capital Nat'l Bank v. CommissionerUnited States Tax Court · 1951
- Player Realty Co. v. CommissionerUnited States Tax Court · 1947
- Ames Trust & Sav. Bank v. CommissionerUnited States Tax Court · 1949
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- La Salle Nat'l Bank v. CommissionerUnited States Tax Court · 1954