United States Board of Tax Appeals March 16, 1925, Docket No. 922 (Appeal of Neuse Manufacturing Co.)

*771OPINION.

Sternhagen :

The taxpayer asserts that the Commissioner’s determination is erroneous for several reasons. It alleges that the present taxpayer is the successor by reorganization of the corporation which operated the business prior to 1912, and that hence the invested capital to be used as the basis of its profits tax must be the invested capital of the old corporation.