COMMERCIAL CREDIT CO. v. TAIT

No. 1736.

2 F.2d 862 (1924)

COMMERCIAL CREDIT CO. v. TAIT, Internal Revenue Collector.

District Court, D. Maryland.

December 22, 1924.


Attorney(s) appearing for the Case

Sylvan Hayes Lauchheimer and Malcolm H. Lauchheimer, both of Baltimore, Md., for plaintiff.

Amos W. W. Woodcock, U. S. Atty., of Baltimore, Md., and Nelson T. Hartson, Sol. of Internal Revenue, and Chester A. Gwinn, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for defendant.


SOPER, District Judge.

The Commercial Credit Company, a Delaware corporation, on January 21, 1924, issued 48,000 additional shares of common stock, without par value, each share thereof having an actual value of $22.50. One hundred and thirty-two certificates of stock were issued in varying amounts. The company paid as an issue tax, pursuant to title 11, § 1107, schedule A-2, of the Revenue Act of 1921 (42 Stat. 227, 301...

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