F. BRODY AND SONS CO. v. COMMISSIONER

Docket No. 12128.

11 T.C. 298 (1948)

F. BRODY AND SONS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 16, 1948.


Attorney(s) appearing for the Case

James F. Swift, Esq., for the petitioner.

George E. Gibson, Esq., for the respondent.


The Commissioner determined a deficiency of $13,103.92 in petitioner's excess profits tax liability for the taxable year ended December 31, 1943. The deficiency resulted from the Commissioner's refusal to permit the taxpayer to include in its equity invested capital for 1943 the sum of $275,000 which the petitioner claimed to have received for an issue of stock in 1918. The Commissioner contended that the taxpayer had received at that time but $47,562.37 for the stock. This...

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