United States Board of Tax Appeals February 7, 1929, Docket No. 16413. (Mutual Cotton Mills Co. v. Commissioner)

lead-opinion

*249OPINION.

Littleton :

The Commissioner has included the collateral notes of subscribers to class B stock in invested capital at the values of $37,386 for 1920, and $49,044 for 1921, The petitioner contends *250that these notes should have been included in the invested capital of both years at their aggregate .face value, which it alleges is $80,000.