Christman Co. v. Commissioner
United States Tax Court
1. Excess Profits Tax -- Equity Invested Capital -- Section 718 (a) (2), I. R. C. -- Amounts of cash and property paid in for shares must be reduced in computing equity invested capital by corresponding amounts of capital later paid out by the petitioner in reacquiring its own shares. 2. Deductions -- Officers' Salaries. -- The total amount paid to three officers, held deductible under section 23 (a) (1) (A) as reasonable compensation for services rendered.
1Opinion of the Court
OPINION.
MuRdock, Judge:
The issue in regard to equity invested capital requires a brief explanation. The Commissioner allowed a larger excess profits credit for each of the years here involved than the petitioner claimed on its returns. He recognized that the petitioner had made an error in considering that outstanding stock went into equity invested capital at $5 per share instead of at $10, the amount originally paid for each share. The question here is, what was the amount of the petitioner’s equity invested capital under section 718, of the Internal Revenue Code.1 The respondent contends…
2Cases cited2 opinions
- West Constr. Co. v. CommissionerUnited States Tax Court · 1946
- Ralphs-Pugh Co. v. CommissionerUnited States Tax Court · 1946
3Cited by9 opinions
- Victory Glass, Inc. v. CommissionerUnited States Tax Court · 1948
- Allegheny Forging Co. v. CommissionerUnited States Tax Court · 1947
- Christman Co. v. CommissionerUnited States Tax Court · 1947
- Esrenco Truck Co. v. CommissionerUnited States Tax Court · 1963
- Italian American Grocery Co. v. CommissionerUnited States Tax Court · 1947
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