United States Board of Tax Appeals May 27, 1925, Docket No. 1837 (Appeal of Wright's Automatic Tobacco Packing Machine Co.)

*1263OPINION.

Phillips :

The taxpayer alleges two errors on the part of the Commissioner: (1) That the entire capital stock has been eliminated in computing invested capital; and (2) that depreciation has not been allowed on patents owned by the corporation and valued on March 1, 1913, at $225,000.

Prior to the organization of the taxpayer corporation in 1893, E. H.