Federal Corporate Income Taxes

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Federal Corporate Income Taxes
E E Emerson Emanuel Rossmoore
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Intangible property purchased after March 3, 1917, with shares of the capital stock of a cor- poration may in no instance be included in the invested capital of the purchasing company under the Revenue Act of 1917 at a value in excess of that at which the selling company would have been entitled to include such intan- gible property in its invested capital under the Revenue Act of 1917, had no change in owner- ship occurred.
Most contracts are intangible property and in Contracts. 115 FEDERAL C
...ORPORATE INCOME TAXES the absence of a ruling to the contrary by the Commissioner of Internal Revenue should be so regarded for the purpose of making returns. Contracts are regarded as tangible property only when they relate to rights in tangible prop- erty to such an extent that their value arises chiefly therefrom. Leaseholds and casinghead gas contracts are illustrative of the class of con- tracts that are regarded as tangible property. Often a taxpayer attempts to set up or appre- ciate patents or goodwill in connection with the payment of a stock dividend or of a credit to surplus, but this practice is incorrect and the entire amount of such items thus created will be disallowed.

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