Langley & Michaels Co. v. Commissioner

MaRQuette:

This proceeding is for the redetermination of a deficiency in income and profits tax for the year 1920 in the amount of $2,287.43. Only so much of the deficiency -is in controversy as arises from the exclusion from the petitioner’s invested capital of certain promissory notes given to the petitioner in payment for shares of its capital stock.

FINDINGS OF FACT.

The petitioner is and was during the year 1920 a California corporation engaged in the wholesale drug business at San Francisco. Its outstanding capital stock during the year 1920 was of the par value of more than $1,200,000, of…