City Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. Where no sufficient depreciation, based upon the probable useful life of depreciable assets, has been taken by the taxpayer for years prior to the taxable year in question there is no presumption that the earned surplus shown on taxpayer's books of account is correct for the purpose of computing invested capital.
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1. Where no sufficient depreciation, based upon the probable useful life of depreciable assets, has been taken by the taxpayer for years prior to the taxable year in question there is no presumption that the earned surplus shown on taxpayer's books of account is correct for the purpose of computing invested capital. Decisions in the Appeals of Cleveland Home Brewing Co.,1 B.T.A. 87; Russell Milling Co.,1 B.T.A. 194, and Rub-No-More Co.,1 B.T.A. 228, considered and distinguished. 2. In computing earned surplus, unrealized appreciation can not be used to offset depreciation sustained on…
1Opinion of the Court
APPEAL OF CITY NATIONAL BANK.
City Nat'l Bank v. Commissioner
Docket No. 1792.
United States Board of Tax Appeals
2 B.T.A. 623; 1925 BTA LEXIS 2317;
September 28, 1925, Decided Submitted July 18, 1925.
1. Where no sufficient depreciation, based upon the probable useful life of depreciable assets, has been taken by the taxpayer for years prior to the taxable year in question there is no presumption that the earned surplus shown on taxpayer's books of account is correct for the purpose of computing invested capital. Decisions in the Appeals of Cleveland Home Brewing Co.,1 B.T.A. 87; Russell Milling…
2Cases cited3 opinions
- Cleveland Home Brewing Co. v. CommissionerUnited States Board of Tax Appeals · 1924
- Russell Milling Co. v. CommissionerUnited States Board of Tax Appeals · 1924
- City Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1925