Legal Opinion

Christman Co. v. Commissioner

United States Tax Court

Decided March 31, 1947No. Docket No. 9284Published

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

The Christman Company, a Michigan Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Christman Co. v. Commissioner

Docket No. 9284

United States Tax Court

8 T.C. 679; 1947 U.S. Tax Ct. LEXIS 239;

March 31, 1947, Promulgated

Decision will be entered under Rule 50.

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'…

2Cases cited3 opinions

  1. West Constr. Co. v. CommissionerUnited States Tax Court · 1946
  2. Ralphs-Pugh Co. v. CommissionerUnited States Tax Court · 1946
  3. Christman Co. v. CommissionerUnited States Tax Court · 1947

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