Tri-State Realty Co. v. Commissioner
United States Tax Court
Upon the facts, held, the credit balances of an open account in petitioner's accounts payable ledger did not constitute equity invested capital within the meaning of section 718 (a) of the Internal Revenue Code prior to April 18, 1942.
1Opinion of the Court
OPINION.
Hill, Judge:
The question we have to decide is whether the credit balances in the open account on petitioner’s books headed “W. H. Johnson — Account No. 422,” in the respective amounts of $83,444.25, $109,757.40, and $112,000, represented loans or represented paid-in surplus for the years 1940 and 1941 and for that part of 1942 prior to April 18, 1942. Respondent contends that these credit balances represented loans and, therefore, did not constitute equity invested capital as defined by section 718 (a) (1) of the Internal Revenue Code.1 Petitioner, on the other hand, contends that…
2Cases cited1 opinion
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
3Cited by4 opinions
- Washington Inst. of Tech. v. CommissionerUnited States Tax Court · 1951
- Vegetable Farms, Inc. v. CommissionerUnited States Tax Court · 1950
- Tri-State Realty Co. v. CommissionerUnited States Tax Court · 1949
- Vegetable Farms, Inc. v. CommissionerUnited States Tax Court · 1950