Legal Opinion

American Steel Co. v. Commissioner

United States Board of Tax Appeals

Decided March 18, 1925No. Docket No. 669Published

Under section 326(a) of the Revenue Act of 1918, interest-bearing demand promissory notes of solvent and responsible makers, actually and bona fide paid in for common and preferred stock of a Pennsylvania corporation, constitute invested capital of such corporation at the time paid in to the extent of their actual cash value.

1Opinion of the Court

Appeal of AMERICAN STEEL CO.

American Steel Co. v. Commissioner

Docket No. 669.

United States Board of Tax Appeals

1 B.T.A. 839; 1925 BTA LEXIS 2789;

March 18, 1925, decided Submitted February 19, 1925.

Under section 326(a) of the Revenue Act of 1918, interest-bearing demand promissory notes of solvent and responsible makers, actually and bona fide paid in for common and preferred stock of a Pennsylvania corporation, constitute invested capital of such corporation at the time paid in to the extent of their actual cash value.

Stewart M. Seymour, Esq., and John W. Drye, Esq., for taxpayer.

Arthur H.…

2Cases cited1 opinion

  1. American Steel Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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