American Steel Co. v. Commissioner
United States Board of Tax Appeals
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
*842OPINION.
Littleton :
The issues presented in this appeal are: (1) Whether, in view of the provisions of the statutes of Pennsylvania (Acts of April 17, 1876, and March 24, 1905), taxpayer is entitled under the provisions of section 326 (a) (2) of the Revenue Act of 1918 to include in invested capital for 1918 the actual cash value of interest-bearing demand promissory notes paid in for stock; and (2) whether the notes amounting in the aggregate to $1,700,000 were in fact bona fide paid in for stock.
The deficiency arises for the most part from the refusal of the Commissioner to allow as a…
2Cited by5 opinions
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