PROSPER SHEVENELL & SON, INC. v. COMMISSIONER

Docket No. 3059.

5 T.C. 88 (1945)

PROSPER SHEVENELL & SON, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 21, 1945.


Attorney(s) appearing for the Case

Edward J. Keelan, Jr., Esq., for the petitioner.

J. T. Haslam, Esq., for the respondent.


OPINION.

ARNOLD, Judge.

Respondent determined a deficiency of $176.83 in petitioner's excess profits tax liability for the taxable year ended November 30, 1941. The sole issue is whether the sum of $105,000 representing the value of stock dividends issued in prior years should be included in petitioner's equity invested capital for excess profits tax purposes. Two other errors alleged by the petitioner were withdrawn.

The stipulated facts...

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