Invested Capital Accounting Based On the Internal Revenue Act of 1918

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The bonds given and the liabilities assumed amount to $190, 000. After pay- ing for the tangibles, we have $17, 000 remaining to apply against intangibles. This amount of intangibles must be allowed, and, in addition, 25% on the $100, 000 stock out- standing at the beginning of the taxable year. Total in- tangibles, $52, 000; paid in for bonds, $17, 000; 25% allow- ance, $25, 000; total intangibles to be included in invested capital, $42, 000; amount to be deducted in line 1, Schedule G, $10, 0...00.
Note that the Regulations state: "at the beginning of the taxable year. " If a corporation files its return on a fiscal year basis, intangible allowance should be computed on the basis of the amount of stock outstanding as at the first day of the corporation's fiscal year, and not on the amount that might have been outstanding at January 1.
A Different Proposition In January, 1910, the Bond Company issued $100, 000 stock, par value, for a patent, and $50, 000 stock for a secret formula. On March 3, 1917, the outstanding capital stock was $600, 000.


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