Central Consumers Wine & Liquor Co. v. Commissioner
United States Board of Tax Appeals
1. A stock subscription agreement of itself is not property, can not be regarded as such under the invested capital provisions of the Revenue Act of 1918, and a corporation may not include in invested capital the amount of unpaid subscriptions to its capital stock. 2. Under the Revenue Acts of 1917 and of 1918, actual values only may be included in invested capital, and the burden of proving actual value is on the taxpayer. 3. Where taxpayer corporation entered into…
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1. A stock subscription agreement of itself is not property, can not be regarded as such under the invested capital provisions of the Revenue Act of 1918, and a corporation may not include in invested capital the amount of unpaid subscriptions to its capital stock. 2. Under the Revenue Acts of 1917 and of 1918, actual values only may be included in invested capital, and the burden of proving actual value is on the taxpayer. 3. Where taxpayer corporation entered into cooperative agreements with retail liquor dealers whereby they became purchasers of its capital stock, and, in consideration of…
1Opinion of the Court
Appeal of CENTRAL CONSUMERS WINE & LIQUOR CO.
Central Consumers Wine & Liquor Co. v. Commissioner
Docket No. 646.
United States Board of Tax Appeals
1 B.T.A. 1190; 1925 BTA LEXIS 2634;
May 21, 1925, decided Submitted March 27, 1925.
1. A stock subscription agreement of itself is not property, can not be regarded as such under the invested capital provisions of the Revenue Act of 1918, and a corporation may not include in invested capital the amount of unpaid subscriptions to its capital stock.
2. Under the Revenue Acts of 1917 and of 1918, actual values only may be included in invested capital, and…
2Cases cited14 opinions
- Sanger v. UptonSupreme Court of the United States · 1875
- Stoddard v. . LumNew York Court of Appeals · 1899
- Bank of China, Japan & the Straits, Ltd. v. MorseNew York Court of Appeals · 1901
- Beals v. Buffalo Expanded Metal Construction Co.Appellate Division of the Supreme Court of the State of New York · 1900
- Dwight & Lloyd Sintering Co. v. CommissionerUnited States Board of Tax Appeals · 1924
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