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MORRIS PLAN COMPANY v. COMMISSIONER

Docket No. 63676.

33 T.C. 720 (1960)

THE MORRIS PLAN COMPANY OF CALIFORNIA, A CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 27, 1960.

Attorney(s) appearing for the Case

F. Daniel Frost III, Esq., and John J. Waller, Esq., for the petitioner.

Aaron S. Resnik, Esq., and John O. Hargrove, Esq., for the respondent.

The Commissioner determined deficiencies in the petitioner's income and excess profits tax of $26,218.84 for 1950, $93,077.59 for 1951, and $147,416.99 for 1952. The primary issue for decision is whether certificates issued by the petitioner and outstanding during the taxable years evidenced "borrowed capital" within the meaning of section 439 of the 1939 Code for the purpose of computing its excess profits credit based upon invested capital. An alternative issue, if the...

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