# Illinois Rural Credit Ass'n v. Commissioner

> United States Board of Tax Appeals · April 3, 1926 · 3 B.T.A. 1178

URL: https://www.frixlaw.com/law-library/cases/4494713

## Case

- **Full name:** APPEAL OF ILLINOIS RURAL CREDIT ASSOCIATION.
- **Court:** United States Board of Tax Appeals
- **Decided:** April 3, 1926
- **Citations:** 3 B.T.A. 1178; 1926 BTA LEXIS 2466
- **Precedential status:** Published
- **Opinion:** Opinion of the court by Graupner
- **Judges:** Phillips, Graupner, Trammell
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4494713

## Opinion text

*1180 OPINION.
■ GRAupneR:
The issue in this appeal is whether the sum of $42,-950, or any part of it, which was paid by subscribers on account of their subscriptions to capital stock of the taxpayer, was income to the taxpayer.
The payments on account of the stock subscriptions, at the time they were made, were undoubtedly capital payments, being made to provide capital for the corporation, and were in its hands capital receipts as distinguished from income. The fact that payments were made in installments and stock was never issued for such payments, because they were not made to the full amount of the subscriptions, does not alter their character.
There is no deficiency and it will be so ordered.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4494713. Public record. Not legal advice.