# Appendix — Ivan Allen Co. v. United States > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386414_0446%3A01 ## Record - **Collection:** Supreme Court brief - **Document type:** Appendix - **Published:** January 1, 1975 - **Citation:** 422 U.S. 617 ## Text 6 3. Taxpayer’s claim is for the recovery of $18,752.27 in principal amount of income taxes and $150,515.85 in prin- cipal amount of accumulated earnings taxes with the in- terest assessed thereon, all of which were erroneously and illegally assessed against and collected from Taxpayer by the Secretary of the Treasury or his delegate for the tax- able years of Taxpayer ended June 30, 1965 and June 30, 1966, respectively. 4. In each of the taxable years in question, Taxpayer kept its books and prepared its Federal income tax re- turns on the accrual basis of accounting. Taxpayer filed its return for each of the said taxable years and paid the tax shown as due thereon to the District Director of In- ternal Revenue Atlanta, Georgia. 5. Upon audit of Taxpayer’s returns for the taxable years in question, the Secretary of the Treasury or his delegate determined; but Taxpayer denies, that the sal- aries which Taxpayer paid Mr. Ivan Allen, Sr. and Mr. Ivan Allen, Jr. constituted unreasonable compensation and could not therefore be deducted as ordinary and neces- sary business expenses under Int. Rev. Code §162(a). The said Secretary or his delegate further determined, but Taxpaycr denies, that Taxpayer had permitted its earnings and profits to accumulate beyond the reasonable needs of its business and that Taxpayer had been formed or availed of for the purpose of avoiding the income tax with respect to its shareholders by permitting its earnings and profits to accumulate instead of being divided or distributed within the meaning of Int. Rev. Code $532. EL TERRES g As a result of the determinations set out in Paragraph 5 above, the Secretary of the Treasury or his delegate as- sessed additional income and accumulated earnings taxes against Taxpayer in the aggregate amount of $87,743.32 for the taxable year 1965 and in the aggregate amount of $81,520.80 for the taxable year 1966. Interest on said ad- ditional income and accumulated earnings taxes was also assessed against Taxpayer by the said Secretary or his delegate in the aggregate amount of $24,755.63 for the taxable year 1965 and in the aggregate amount of $18,108.78 for the taxable year 1966. 7. Taxpayer paid said additional income and accumulated earnings taxes to the Director of the Internal Revenue Service Center, Chamblee, Georgia on or about June 1, 1970 and paid the interest on said additional income and accumulated earnings taxes to the said Director on or about November 20, 1970. 8. On or about October 19, 1970, within the time provided by law, Taxpayer duly filed Claims for Refund of the said amounts of additional income and accumulated earn- ings taxes assessed against and collected from Taxpayer. On or about January 4, 1971, within the time provided by law, Taxpayer duly filed an amendment to the said Claims for Refund to include a claim for the refund of the interest assessed against and collected from Taxpayer on said amounts of additional income and accumulated earnings taxes. No decision has been rendered on the ‘said Claims for Refund, as amended, by the Secretary of the Treasury or his delegate, and more than six months 8 prior to the filing of this suit have expired from the date on which the said Claims for Refund were filed. 9. Copies of the said Claims for Refund for the taxable years in question and the amendments thereto are attached hereto, made a part hereof, and marked Exhibits A through D, respectively. Taxpayer incorporates herein each and every allegation of fact and each and every contention set out in the said Claims for Refund and amendments thereto. 10. For the reasons stated in Taxpayer’s Claims for Re- fund, said additional income and accumulated earnings taxes and the interest thereon were erroneously and il- legally assessed against and collected from Taxpayer by the Secretary of the Treasury or his delegate. i. No part of the aforesaid $18,752.27 of additional in- come taxes nor any part of the aforesaid $150,515.85 of accumulated earnings taxes nor any part of the interest thereon erroneously and illegally assessed against and col- lected from Taxpayer by the Secretary of the Treasury or his delegate for the taxable years in question has been refunded to Taxpayer. 12. By virtue of the aforesaid, the defendant United States of America became and now is indebted to Taxpayer in the full amount of $212,132.53 with interest thereon as provided by law. ” — — om 13. Taxpayer seeks refund herein of said additional in- come and accumulated earnings taxes and the interest thereon erroneously and illegally assessed against and col- lected from Taxpayer, with interest thereon from the dates of payment as provided by law, or such greater amount as may be legally refundable. 14. Taxpayer has complied with all conditions precedent to the bringing of this suit. WHEREFORE, Taxpayer prays that judgment be en- tered in its favor in the amount of $212,132.53 with interest thereon as provided by law, or in such greater amount as may be legally refundable, that the Court grant such other relief as it may deem proper, and that Taxpayer be awarded its costs. King & Spalding /s/ Kirk A. McAlpin /s/ Stanley W. Rosenkranz /s/ Herschel M. Bloom Attorneys for the Plaintiff Ivan Allen Company 2500 Trust Company of Georgia Building Atlanta, Georgia 30303 404/577-5350 PPS RE PARR erred samme es 2 ot ball | I~ NO WTN ON @DWO}H POOR COPY - Exhibit A -- — ne eee + Le ree a tre ee ‘en arr sal brvbran feb Ut tte . oe ’ “ 0°35 ra ok a 4 (bite! vet ites Rely LYE} TO PIED WITHTHE DeteiCh DIELCTOr WHERI ASSLSSMERT WAS MADE OR TAK PAID The Diath t Daecter > nN ercdecote an ‘the block below the bend bind of cham filed, on! on mn, sa hes cite ned {J Refund of Toxes Ile jolly, Crroncously, or Uxcessively Collected. a! Refund of Amount Paid for Stemps Unused, or Used in Crror or Excess. O Abatement of Tax Assessed (not applicoble to cstote, gift, or income taxes). 7 PLE/ SE TYE OR PRINT PLAINLY Nome of toapayer of purchoser of stomps Ivan Allen Comp..ny Number ond street =—_ } City, town, State, Posto! /1P Code P.O. Box 1712 ! Atlanta, Georgia 30301 Fillin cpplicette iten: sh Hach letter size sheet: :. spose is not su.sicicnt oe. Your socic’ security number iia s number, if yount return b. if on employee, enter employer identification number : : : ‘ F ~ : ee ——— 58-0136820 a c. Distret in which return (if ony) wos filed d Nome ond oddress show: on return, if different from obove Dis. Dir. Ga. same e. Period — if for tox reported on onnva! basis, prepare seporote form for each toxoble yeor | f. Kund of tox from July 1 .1964.te June 30 1965 Income __ g. Amount of oss. snert : Dates of poyment "$885. ,.00: 10/1 5/64 4; $885. 5.00: 12/15/64; _ $252, 127.62 $22, 125.09:4/15/65; $22.125.00: 26/15/65; $60,000:9/2/65 h h. Date s: stamps amps were purchesed from from os pope = be: dd eee tox, $ 54, 118.9531 fl 7/653 : Government ; complete computation below) $ 91 ia 88 . 67 26/1/70 $87,747.32 | s k Thec cnt believes thot this cian should | Le ollc- ed for the foliz. ng reasons See Attached Statement COMPUTATIC'Y OF INCCIME TAX REFUND Income Tox . Tax withheld . Estimated tox poid ._.. eee wears . Tox paid with original return... 2... i) . Any additional income tox poid .... 91. 3 3B eo . Total tox poid (Add lines 1-4). . “252, 127. 62 Less: Your computatian of correct tox | 164, 380. 30 87,747. 32* =0= 87, 747.32° . Amount of overpoyin st . Amount previously ref ‘ed eo ONOWR WN > « Net overpayment tEnts riniteni cheval Under penaltics a perjury, | cectare ticct thes claim, incluciag any occompanying schedules and statements, has been cxanuned by me -nd to the best of my knowledge anil belief it is true end correct SEC INSTRUCHIONS ON raVERSE FORI, 843 (: ov. 7-65) such greater asount as may be leqaliy refw dable. 12 STATEMENT ATTACHED TO AND FORMING A PART OF THE CLAIM OF IVAN ALLEN COMPANY FOR REFUND OF INCOME AND ACCUMULATED EARN- INGS TAXES PAID FOR THE TAXABLE YEAR 1965 I. Salary Paid by Taxpayer to Ivan Allen, Sr. A. Statement of Facts During the taxable year in question and during all the years of its existence, Ivan Allen Company (hereinafter referred to as “Taxpayer”), was engaged in the office supply business. _ Taxpayer was founded in 1899 by Mr. Ivan Allen, Sr. and Mr. J. W. Fielder. At that time, the office supply business was unique, and Ivan Allen, Sr. may well have been its originator. He was undoubtedly the first in the southeast to visualize the idea of a department store of office equipment. The business prospered in the early 1900’s, and in 1920, Mr. Allen, Sr. was elected President of Taxpayer. In 1938 he became Chairman of Taxpayer’s Board of Di- rectors and served in this position until his death. During a substantial portion of the period in which he served Taxpayer as President and Chairman of its Board of Directors, Mr. Allen, Sr. had the primary respon- sibility for the management and supervision of Taxpayer’s business and was undoubtedly the major factor in its suc- cess and growth. Moreover, Mr. Allen, Sr. was responsi- ble for a number of innovations in the office supply busi- ness, all of which contributed to Taxpayer’s success. He originated.an inventory control plan, which for years has been the most widely used plan in the business. With minor improvements, both the standard accounting forms and cost oft doing business forms which Mr. Allen, Sr. 13 developed are still being used. He developed the quintup- let charge and billing system whereby the invoice, charge, delivery ticket, statistical record and salesman’s slip are all made in one operation. Finally, Mr. Allen, Sr. was the first to capitalize on the use of “visual education” in the business. Indeed, as early as 1923, he suggested using films to demonstrate the various manufacturing pro- cesses and facilities connected with the stationer’s industry. Mr. Allen, Sr. was not only a successful business- man but also took an active part in numerous civic activi- ties. He served as President of the Atlanta Chamber of Commerce, as President of the Southeastern Fair Associa- tion and was the first President of the Atlanta Convention Bureau. He served as a member of a small committee which raised the first substantial funds for the Atlanta area Boy Scouts and for many years served on the Execu- tive Committee of the Council of Boy Scouts. Mr. Allen, Sr. was one of the original members of the Agriculture and Industrial Development Board of Georgia. He served as Chairman of the Forward Atlanta Commission, of the Fulton County Department of Public Welfare, and of a Committee which raised funds to reestablish Oglethorpe University. Finally, Mr. Allen, Sr.’s close relationship with President Franklin D. Roosevelt led to his appointment as Chairman of the Federal Home Loan Bank in the south- east and as Chairman of the Franklin D. Roosevelt Warm Springs Memorial Commission. Thus, while Mr. Allen, Sr. was implementing the many innovations in the office supply business which he had developed, he was also engaged in various civic activities which drew attention to and created respect for both Tax- payer and Mr. Allen, Sr. It was this combination of Mr. Allen, Sr.’s business acumen and his various civic activities which led to Taxpayer’s growth into a highly successful company. RE — re RD PETS RNNNNECEmENNEIaEeemenEneereeeeecen 14 Notwithstanding Mr. Allen, Sr.’s role in Taxpayer’s success, his salary was always extremely modest. Indeed, throughout his years of service to Taxpayer, Mr. Allen, Sr. was paid a salary which was always less than Tax- payer’s leading salesman, and frequently less than several of Taxpayer’s salesmen. In 1964, Mr. Allen, Sr. suffered a stroke which cur- tailed his activities with Taxpayer. At that time, he had served Taxpayer for more than 64 years, always at a very modest salary. Even after his sickness, however, Mr. Allen, Sr. continued to serve Taxpayer in a consulting capacity. In consideration of his services as a consultant and for the many years of service in which he was the major factor in Taxpayer’s development, Taxpayer con- tinued to pay him the very modest annual salary of $12,525.16. Taxpayer deducted the amount of the salary which it paid to Mr. Allen, Sr. as an ordinary and necessary business expense for its taxable year 1965. The Commis- sioner determined, however, that the amount paid to Mr. Allen, Sr. constituted unreasonable compensation and that the payment should not therefore have been deducted. Accordingly, the Commissioner assessed a deficiency against Taxpayer for its taxable year 1965. Taxpayer has paid the deficiency. This claim is filed for the refund of the deficiency so paid, with interest thereon as provided by law, or such greater amount as may be legally refundable. B. Tazxpayer’s Contentions (1) The amount which Taxpayer paid to Mr. Ivan Allen, Sr. constituted a reasonable salary for both past and present personal services actually rendered to Tax- payer within the meaning of Int. Rev. Code §162(a) (1). 15 The amount which Taxpayer paid to Mr. Allen, Sr. was, therefore, an ordinary and necessary business expense within the meaning of Int. Rev. Code §162(a). (2) Under the contention stated above, the amount which Taxpayer paid to Mr. Allen, Sr. was properly de- ducted by Taxpayer under Int. Rev. Code §162(a). Accord- ingly, the deficiency assessed against and paid by Taxpayer constitutes an overpayment for which Taxpayer is entitled to a refund. II. Salary Paid by Taxpayer to Ivan Allen, Jr. A. Statement of Facts Ivan Allen, Jr. was employed by Taxpayer in 1933. In 1938 he became Secretary-Treasurer of Taxpayer. In 1946 he was elected President of Taxpayer and in 1957 became Vice Chairman of Taxpayer’s Board of Directors. In 1962, Mr. Allen, Jr. was elected Mayor of the City of Atlanta and served in this capacity during the taxable year in question. Although his duties as Mayor limited the time which Mr. Allen, Jr. was able to spend on Tax- payer’s routine matters, he continued to serve as Tax- payer’s chief policy maker. For example, Mr. Allen, Jr. continued to receive daily communications with respect to the business problems confronting Taxpayer and often made daily responses. He continued to review all internal financial reports, including inventory and sales data, and was in frequent consultation with Taxpayer’s officers with respect to merchandising lines, sales, personnel matters, inventory, accounting, and market extension. Mr. Allen, Jr. continued to determine both Taxpayer’s sales policies and the character of its advertising and promotional opera- tions. He also continued his primary decision making role with respect to Taxpayer’s major expenditures, including 16 not only capital expenditures but also contributions to the Ivan Allen Company Foundation and to Taxpayer’s profit sharing plan. In short, Taxpayer made no policy decision of any significance during the taxable year in question without first obtaining the advice and approval of Mr. Allen, Jr. Even prior to becoming Mayor of Atlanta, Mr. Allen, Jr., like his father, contributed to Taxpayer’s success by spending at least one-half of his working time engaged in civic and outside business activities. Nevertheless, Tax- payer’s success during these years clearly attest to Mr. Allen, Jr.’s ability to operate Taxpayer while spending a substantial portion of his time engaged in activities other than the management and supervision of Taxpayer’s af- fairs. In 1948, Taxpayer paid Mr. Allen, Jr. a very modest salary of $12,000. As his responsibility and value to Tax- payer grew, Mr. Allen, Jr.’s salary was increased to $30,000. When Mr. Allen, Jr. became Mayor of Atlanta, however, Taxpayer recognized that the amount of time that he could spend on its affairs would be curtailed. Accordingly, be- ginning in 1962 and including the taxable year in question, Taxpayer reduced Mr. Allen’s salary to $15,025.08. During the taxable year 1965, Taxpayer paid its presi- dent, Mr. W. H. Glenn, a salary of $31,000, approximately double that of Mr. Allen, Jr. In the same year, nine of Taxpayer’s salesmen received salaries greater than that of Mr. Allen, Jr. Taxpayer deducted the amount of the salary which it paid to Mr. Allen, Jr. as an ordinary and necessary business expense for its taxable year 1965. The Commis- sioner determined, however, that the amount paid to Mr. Allen, Jr. constituted unreasonable compensation and that _ 17 the payment was not therefore deductible. Accordingly, the Commissioner assessed a deficiency against Taxpayer for its taxable year 1965. Taxpayer has paid the deficiency. This claim is filed for the refund of the deficiency so paid, with interest thereon as provided by law, or such greater amount as may be legally refundable. \ B. Taxpayer’s Contentions (1) The amount which Taxpayer paid to Mr. Allen, Jr. constituted a reasonable salary for personal services actually rendered to Taxpayer within the meaning of Int. Rev. Code §162(a) (1). The amount which Taxpayer paid to Mr. Allen, Jr. was, therefore, an ordinary and necessary business expense within the meaning of Int. Rev. Code §162(a). (2) Under the contention stated above, the amount which Taxpayer paid to Mr. Allen, Jr. was properly de- ducted by Taxpayer under Int. Rev. Code §162(a). . Ac- cordingly, the deficiency assessed against and paid by Tax- payer constitutes an overpayment for which Taxpayer is entitled to a refund. III. Accumulated Earnings Tax A. Statement of Facts Taxpayer’s shareholders as of June 30, 1965 were as follows: No. of Shares Allen, Beaumont 925 Allen, Hugh Inman 2615 Allen, Irene Beaumont 2265 Allen, Ivan Sr. 5650 Allen, Ivan Jr. ; 4580 18 Allen, Ivan Jr. Trustee U/W Charles M. Marshall 9650 Allen, Ivan III , 2365 Allen, Ivan IV 110 Allen, Louise R. . 2115 Allen, Margaret Poer - 4 ee)! Ball, Jack T. 20 Brumbelow, Morris 10 Carnes, John 850 _ Dickerson, Elmer : 300 Estes, Robert S. . . 40 . Floyd, W. F. Jr. | 515 Glenn, W. H. 2400 Hampton, James F. 25° Harris, Andrew D. 2 Harris, Grady W. . 2 Harris, W. D. | | 475 Jones, Hayden C. Jr. 575 ‘ Lanier, D. B. 100 Layton, Estate of Charles R. 75 Murphy, J. H. 754 Ownby, O. G. | 130 Ownby, O. G. Trustee for Roger Paul 10 Ownby, O. G. Trustee for Scott Alan 10 Patrick, James H. 25 Pettes, Thompson P. 25 Richardson, Walter 20 Snellings, Walter Arnold 22 Tebow, D. L. 200 Williams, J. C. | 500 Wilson, S. W. | 75 Winslow, T. E. | 160 19 As an operating company, Taxpayer has a readily ascertainable operating cycle and a need for sufficient working capital to operate its business through at least one such cycle. Since Taxpayer’s net liquid assets deter- mined as of the end of the taxable year in question which were available for use in meeting its working capital re- quirements were less than its needs, Taxpayer retained a portion of its earnings and profits for the taxable year. For a number of years, including the taxable year in question, Taxpayer has held certain marketable secu- rities. Substantially all of these securities, however, were of corporations engaged in businesses related to that of Taxpayer. Moreover, since most of the securities had greatly appreciated in value, Taxpayer would have had to incur a substantial capital gains tax to convert them into cash. For these reasons, Taxpayer’s management viewed the securities as business investments which were not available either for use in meeting Taxpayer’s reason- able business needs or for distribution to its shareholders. However, even if the cost of Taxpayer’s marketable secu- rities are included in the computation of Taxpayer’s net liquid assets, the cost of one of Taxpayer’s operating cycles for the taxable year in question was still in excess of its net liquid assets determined as of the end of the taxable year. Taxpayer does not have a history of making loans to its shareholders and possesses a record of regular and substantial dividends. Moreover, the income tax conse- quences to Taxpayer’s shareholders have never been con- sidered in determining its dividend policy. Taxpayer’s ratio of current assets to current liabilities for the taxable year in question was extremely small. Indeed, only a very insignificant amount of Taxpayer’s 20 earnings and profits has ever been invested in assets other than assets directly related to the operation of Taxpayer’s business. Nevertheless, the Commissioner determined that Tax- payer had accumulated earnings beyond the reasonable needs of its business and that this accumulation was for the purpose of avoiding the income tax with respect to its shareholders. Accordingly, the Commissioner assessed an accumulated earnings tax deficiency against Taxpayer for its taxable year 1965. Taxpayer has paid the deficiency. This claim is filed for the refund of the deficiency with interest thereon as provided by law, or such greater amount as may be legally refundable. B. Taxpayer’s Contentions (1) The marketable securities which Taxpayer held and which had substantially appreciated in value were not available either for use in meeting Taxpayer’s reason- able business needs or for distribution to its shareholders. For this reason, the marketable securities are excludable in computing Taxpayer’s net liquid assets available for use in its business. The cost of one of Taxpayer’s operat- ing cycles for the taxable year in question thus exceeded its net liquid assets available for use in its business deter- mined as of the end of the taxable year. Consequently, Taxpayer’s earnings and profits for the taxable year in question which it retained were not in excess of and were retained by Taxpayer for the reasonable needs of its busi- ness, including the reasonably anticipated needs of its busi- ness, within the meaning of Int. Rev. Code §535(c). Ac- cordingly, in computing its accumulated taxable income under Int. Rev. Code §535, Taxpayer is entitled to an accumulated earnings credit in an amount at least equal 21 to the amount of its retained earnings and profits for the taxable year in question (or in such lesser amount of its earning and profits for the taxable year in question as may be determined to have been retained by Taxpayer for the reasonable needs of its business, including the reasonably anticipated needs of its business. ) (2) Even if the marketable securities held by Tax- payer are includable in computing Taxpayer’s net liquid assets available for use in its business, which Taxpayer denies, the cost of one of Taxpayer’s operating cycles for the taxable year in question still exceeded its net liquid assets determined as of the end of the taxable year. Con- sequently, Taxpayer’s earnings and profits for the taxable year in question which it retained were not, in excess of and were retained by Taxpayer for the reasonable needs of its business, including the reasonably anticipated needs of its business, within the meaning of Int. Rev. Code §535(c). Accordingly, in computing its accumulated tax- able income under Int. Rev. Code $535, Taxpayer is entitled to an accumulated earnings credit in an amount at least equal to the amount of its retained earning and profits for the taxable year in question (or in such lesser amount of its earnings and profits for the taxable year in ques- tion as may be determined to have been retained by Tax- payer for the reasonable needs of its business, including the reasonably anticipated needs of its business.) (3) Even if the earnings and profits which Taxpayer retained exceeded the reasonable needs of its business, including the reasonably anticipated needs of its business, which Taxpayer denies, such excess was not accumulated by Taxpayer for the purpose of avoiding the income tax with respect to its shareholders. Taxpayer was not, there- fore, formed or availed of for the purpose of avoiding the income tax with respect to its shareholders or the 22 shareholders of any other corporation by permitting its earnings and profits to accumulate instead of being divided and distributed within the meaning of Int. Rev. Code §532 (a). (4) Under any of the alternative contentions stated above, Taxpayer is not subject to an accumulated earnings tax liability under Int. Rev. Code §531 for the taxable year in question. Accordingly, the accumulated earnings tax deficiency assessed against and paid by Taxpayer con- stitutes an overpayment for which Taxpayer is entitled to a refund. _— 23 7 Exhibit B a Dee ctea's Cees foun us Se ameNDED Cie? por ..crunp Mitel wanes Se ne (Date recent) The In: cinat Hevenue Service will inticate in the block Lelow the kind of «claim tiled, and fill in, where required. oO Refund of Taaes Megally, Crroneously, of Lxcessively Collected. a) Refund of Amount Paid for Stamps Unused, or Used im Error or Excess. [J Abatement of Tax Assessed (not applicabic to income, estate or cift taxes). Please Typre or Print Plainly H Name of taxpayer or purchaser of stamps” | IVAN Alu.EN COMPANY Number ands street : City or town, State, and 7'P code P. O. Box 1712 ' Atlanta, Georgia 3030) Fill in applicable items—use attachments if nccessary b. Employer identification number (if any) 58-0136820 d. Name and address shown on return, if different from above a. Your social security number | Wife's number, if joint return Internal Revenue Service of ice where re- turn (if any) was filed Dist. Dir. Georgia same @. Period—if for tax reported on annual 64 prepare separate 30 for each taxable "E5 f. Kind of tax prom UUlY Le 194 2 Tune Income FE oa RUA ney h. Date stamps were purchased from Govern- | i. Amount to b- refumded (If income roy ment complete computation below) $87,747. 32* k. The claimant believes that this clzim should be allo. J for the following reasons: See Attached Statement COMPUTATION OF INCOME TAX REFUND Income Tax 1 Tax withheld... s 2 «8 © © 6 ee 8 8 6 we we 8 ee 6 8 wm Iecw ews ngninn senpn ta eareanas pecess see 2 Estimated tax paid. 2. 2. 2 1 6 6 ew we we ee ee ee ee ee 46s 020.00 ose 3 Tax paid with original return. 2. 6 6 6 we ke ee ee ee ee ee ee wey: 3 i8. 95. es 4 Any ac’ ‘tional income tax paid. 2 2. 1. 1 ew ew ee ee ee ew we 91, 788. 67 5 Total tax paid (add lines 1-4). ww wwe wee ee ee ee ee ee ee 6 Less: Your computation of correcttax. . 2. 2. 2. 1 6 ee ee we ee ee et , 7 Amount of overpayment. 2. 2 2 6 6 ee ew ee ee ee ee ee ws 8 Amount previously refunded. . 2. 2. 6 6 6 ew we ee ee ee ee 9 Net overpayment (enter in itemiabove). . 2. 2. 2. 2. ew ee we eee ee 7, 747. 32* © iN nf i ‘al ~ >. ve ~) ea Under penalties of perjury, |! declaf® that | have exami:.cd this claim, including accompanying schedules and statements, and to the best of my knowledge and belief it is truc, correct, and complete. DAO onions sc snsesescveccsanecseveesescsceecesenetessicns tesessceeeee DGC occas scccccccsvccccndnerccscdenvesceesesceesecg BDecsvsces. Sn nnerlusospsieheshevseconseadsccdenoseauins ceusasseenssegsannesiacdesdssensiesunsrseiwas spuunaue Coseete get teatentsRemeenea *P1TS' assessed interest, wil if MAVWSUCS OC’ EREPSon as providde #8 1atyy to” such qreater amount as mav be legally retundabie. -- Se me etre rem ae: ~s s ewes i ns Sorat er oe 24 STATEMENT AMENDING IVAN ALLEN COMPANY’S CLAIM FOR REFUND OF INCOME AND ACCUMU- LATED EARNINCS TAXES PAID FOR THE TAXABLE YEAR 7/1/64-6/30/65 On October 19, 1970, Ivan Allen Company (herein- after referred to as ‘““Taxpayer’’) filed a Claim For Refund (“Claim”) of income and accumulated earnings taxes paid for its taxable year 1965. This statement is filed to amend Taxpayer’s previously filed Claim as follows: (1) The Form 843 previously filed by Taxpayer is hereby amended in accordance with the Form 843 attached hereto and styled ‘““Amended Claim for Refund.” (2) The “STATEMENT ATTACHED TO AND FORMING A PART OF THE CLAIM OF IVAN ALLEN COMPANY FOR REFUND OF INCOME AND ACCUMU- LATED EARNINGS TAXES PAID FOR THE TAXABLE YEAR 1965” is hereby amended as follows: (a) PAGE 4, SECOND FULL PARAGRAPH, which reads: “Taxpayer has paid the deficiency. This claim is filed for refund of the deficiency so paid, with interest thereon as provided by law, or such greater amount as may be legally refundable.” is hereby amended to read as follows (changes italicized) : “Taxpayer has paid the deficiency with in- terest thereon. This claim is filed for the refund of the deficiency and interest so paid, with interest thereon as provided by law, or such greater amount as may be legally re- fundable.” 25 (b): PAGE 4, CONTENTION (2) is hereby amended to read as follows (changes italicized) : “(2) Under the contention stated above, the amount which Taxpayer paid to Mr. Allen, Sr. was properly deducted by taxpayer un- der Int. Rev. Code §162(a). Accordingly, the deficiency and interest thereon assessed against and paid by Taxpayer constitutes an overpayment for which Taxpayer is entitled to a refund.” (c) PAGE 7, THIRD PARAGRAPH, which reads: “Taxpayer has paid the deficiency. This claim is filed for the refund of the deficiency so paid, with interest thereon as provided by law, or such greater amount as may be le- gally refundable.” is hereby amended to read as follows (changes italicized) : “Taxpayer has paid the deficiency with in- terest thereon. This claim is filed for the refund of the deficiency and interest so paid, with interest thereon as provided by law, or. such greater amount as may be legally re- fundable.” (d) PAGE 8, CONTENTION (2) is hereby amended to read as follows (changes italicized) : “(2) Under the contention stated above, the amount which Taxpayer paid to Mr. Allen, Jr. was properly deducted by Taxpayer under Int. Rev. Code §162(a). Accordingly, the de- ficiency and interest thereon assessed against 26 : A and paid by Taxpayer constitutes an overpay- ment for which Taxpayer is entitled to a re- fund. ~- (e) PAGE 10, SECOND PARAGRAPH, which reads: “For a number of years, including the taxable year in question, Taxpayer has held certain marketable ‘securities. Substantially all of these securities, however, were of corporations engaged in businesses related to that of Tax- payer. Moreover, since most of the securities had greatly appreciated in value, Taxpayer would have had to incur a substantial capital gains tax to convert them into cash. For these reasons, Laxpayer’s management viewed the securities as business investments which were not available either for use in meeting Taxpayer’s reasonable business needs or for distribution to its shareholders. However, even if the cost of Taxpayer’s marketable se- curities are included in the computation of Taxpayer’s net liquid assets, the cost of one of Taxpayer’s operating cycles for the taxable year in question was stifl in excess of its net liquid assets determined as of the end of the taxable year.” is hereby amended to read as follows (changes italicized) : “For a number of years, including the taxable year in question, Taxpayer has held certain marketable securities. Substantially all of these securities, however, were of corporations engaged in businesses related to that of Tax- payer. Moreover, since most of the securities 27 had greatly appreciated in value, Taxpayer would have had to incur a substantial capital gains tax to convert them into cash. For these reasons, Taxpayer’s management did not view the securities as a part of Taxpayer’s net liquid assets. Rather, the securities were viewed as long-term business investments which were neither available for use in meet- ing Taxpayer’s reasonable business needs nor generally available for distribution to its shareholders. However, even if the cost of Taxpayer’s marketable securities are included in the computation of Taxpayer’s net liquid assets, the cost of one of Taxpayer’s operating cycles for the taxable year in question was still in excess of its net liquid assets deter- mined as of the end of the taxable year.” (f) PAGE 11, FOURTH PARAGRAPH, which reads: “Taxpayer has paid the deficiency. This claim is filed for refund of the deficiency with interest thereon as provided by law, or such greater amount as may be legally refund- able.” is hereby amended to read as follows (changes italicized) : “Taxpayer has paid the deficiency with inter- est thereon. The deficiency was paid within ten days of the receipt of notice and demand issued in connection therewith. This claim is filed for the refund of ti. ueficiency and interest so paid with interest thereon as pro- vided by law, or such greater amount as may be legally refundable.” 28 (g) PAGE 11, CONTENTION (1), FIRST SEN- TENCE is hereby amended to read as follows (changes italicized) : “(1) The marketable securities which Tax- payer held and which had substantially ap- preciated in value were neither available for use in meeting Taxpayer’s reasonable business needs nor generally available for distribution to its shareholders.” (h) PAGE 14, CONTENTION (4), is hereby amended to read as follows (changes italicized): “(4) Under any of the alternative conten- tions stated above, Taxpayer is not subject to an accumulated earnings tax liability under Int. Rev. Code §531 for the taxable year in question. ‘Accordingly, the accumulated earn- ings tax deficiency and interest thereon as- sessed against and paid by Taxpayer consti- tutes an overpayment for which Taxpayer is entitled to a refund.” (i) PAGE 14 is hereby amended to add the following contentions (5), (6) and (7) with respect to the interest paid by Taxpayer on the accumulated earnings tax assessed against it: “(5) The accumulated earnings tax imposed by Int. Rev. Code §531 is not a “tax” within the meaning of Int. Rev. Code §6601(a). Rather, it is either an “assessable penalty, additional amount or addition to the tax” within the meaning of Int. Rev. Code §6601 (f) (3). Interest on such a penalty, additional amount, or addition to the tax can be imposed only if it is not paid within ten days from the 29 date of notice and demand. Taxpayer paid the accumulated earnings tax deficiency as- sessed against it within ten days of the re- ceipt of notice and demand. Accordingly, even if an accumulated earnings tax was prop- . erly assessed against Taxpayer, which Tax- payer denies, Taxpayer is not liable for any interest on such tax.” “(6) Even if the accumulated earnings tax is a ‘tax’ within the meaning of Int. Rev. Code §6601(a), which Taxpayer denies, by virtue of Int. Rev. Code §6155, the ‘last date prescribed for payment’ of such tax under Int. Rev. Code §6601(a) is the date of notice and demand. Interest can therefore be imposed on an accumulated earnings tax deficiency only from the date of notice and demand to the date of payment, unless payment is made within ten days of notice and demand in which case Int. Rev. Code §6601 (f) (4) pre- cludes the imposition of any interest. , Tax- payer paid the accumulated earnings tax as- sessed against it within ten days of the receipt of notice and demand. Consequently, even if an accumulated earnings tax was properly assessed against Taxpayer, which Taxpayer denies, Taxpayer is not liable for any interest on such tax.” “(7) Under either of the alternative conten- tions (5) or (6) stated above, Taxpayer is not liable for any interest on the accumulated earnings tax assessed against it for the tax- able year in question. Accordingly, even if _ 30 an accumulated earnings tax was properly as- sessed against Taxpayer, which Taxpayer denies, the interest assessed against and paid by Taxpayer with respect to such tax con- stitutes an overpayment for which Taxpayer is entitled to a refund. —- 31, Exhibit C o- a on (ret ' . . pe . ( obs tbe | woh in mutty y. Vt DE rh bnene nok WH | ah MD Sett POL VAS TAA Gn TAM PAID ' Wat WO et the nedon ete ae Me EE Bee Be Dene Dat eb anne Caled, evel Goll an, wlio ees ccaqanee il - {. | Ke fete b ben OMe qally, Lie ecusly, or Pacecsively Collected, {. ] Petal of Acro: Bord for tories Uauod, of Urdd in teens ew Une *S, \ [. | Abatement of Ton Agee (net oppheaty le toe stote, gift, o income taxes). a _PILASETYPT CS PR PLAY Peon of taeg: 6 Oe CO Ce IVAN AbD COR ) ‘i, r _ Hun ber por sheet i Cuy, town, Stote, Postel 21? Code aoe Nox 17)?_ __t Atlanta, Georgi a__ 30301 a _billines “inligetale iiem—/, ftuchiaiter tie shoots if rpuce is not suticie nt 6. “Your P tnciol secunty nomen w: fe's ovale, f jount return b. Wow employer, enter em ployer identilicotvon number $e fo bE, 58 -0236820 _ Ps Distt wn which retorn (Hf ony) wos 9 fis r d. Nome ond oddress shown on return, of dierent from chove pis. Dir. Georgia 7 same e. Perod—-if for tox reponed on annul boon, prepare separ ‘e form tor gach ch taruble yeor 1, Kind of tox from July 1 + 65.'e June _ 30 9 66[.. Income_ tf. Amun of cucnmeant 1Dens of poyment $3, 200212/15/65; $15,800.20: 3715/6675 | $325,671.00... $15,799. 80: 6/9/63 ; $100,102.50: 9/15/66; $100, 39 of . DX eeere ert stetatintin tit Mi de h. Dote stone v cre purchosed i: rom i. hanount fo be & tunded ( aw income 2 10%, i. Ann ne, 4837 eo oF Government complete computation below) gift $90, 616. 14: 6/1/70 . ‘ et. _|.s 81,520.80 $ k. The for use in meet- ing Taxpayer’s reasonab'e » ness needs nor generally available for dix a:tion to its shareholders. However, eve’ the cost of Taxpayer’s marketable securitie ‘e included in the computation of Taxpaye.’s et liquid assets, the cost of one of Taxpayer’s « verating _ cycles for the taxable year in questicn was still in excess of its net liquid assets deter- mined as of the end of the taxable year.” (f) PAGE 11, FOURTH PARAGRAPH, which reads: “Taxpayer has paid the deficiency. This claim is filed for refund of the deficiency with interest thereon as provided by law, or such greater amount as may be legally refund- able.” is hereby amended to read as follows (changes italicized): “Taxpayer has paid the deficiency with inter- est thereon. The deficiency was paid within ten days of the receipt of notice and demand issued in connection therewith. This claim is filed for the refund of the deficiency and interest so paid with interest thereon as pro- vided by law, or such greater amount as may be legally refundable.” (g) PAGE 11, CONTENTION (1), FIRST SEN- TENCE is hereby amended to read as follows (charges italicized): 48 “(1) The marketable securities which Tax- payer held and which had substantially ap- preciated in value were neither available for use in meeting Taxpayer’s reasonable business needs nor generally available for distribution to its shareholders.” (h) PAGE 14, CONTENTION (4), is hereby amended to read as follows (changes italicized): “(4) Under any of the alternative conten- tions stated above, Taxpayer is not subject to an accumulated earnings tax liability under Int. Rev. Code §531 for the taxable year in question. Accordingly, the accumulated earn- ings tax deficiency and interest thereon assessed against and paid hy Taxpayer con- stitutes an overpayment for which Taxpayer is entitled to a refund.” (i) PAGE 14 is hereby amended to ade the following contentions (5), (6) and (7) with respect to the interest paid by Taxpayer on the accumuldted ’ earnings tax assessed against it: “(5) The accumulated earnings tax imposed by Int. Rev. Code §531 is not a ‘tax’ within the meaning of Int. Rev. Code §6601(a).. Rather, it is either an ‘assessable penalty, additional amount or addition to the tax’ within the meaning of Int. Rev. Code §6601 (f) (3). Interest on such a penalty, addi- tional amount, or addition to the tax can be imposed only if it is not paid within ten days from the date of notice and demand. -Tax- “payer paid the accumulated earnings tax de- ficiency assessed against it within ten days of 49 the receipt of notice and demand. Accord- ingly, even if an accumulated earnings tax was properly assessed against Taxpayer, which Taxpayer denies, Taxpayer is not li- able for any interest on such tax.” “(6) Even if the accumulated earnings tax is a ‘tax’ within the meaning of Int. Rev. Code §6601(a), which Taxpayer denies, by virtue of Int. Rev. Code §6155, the ‘last date prescribed for payment’ of such tax under Int. Rev. Code §6601(a) is the date of notice and demand. Interest can therefore be im- posed on an accumulated earnings tax defi- ciency only from the date of notice and de- mand to the date of payment, unless payment is made within ten days of notice and demand in which case Int. Rev. Code §6601 (f) (4) pre- cludes the imposition of any interest. Tax- payer paid the accumulated earnings tax assessed against it within ten days of the receipt of notice and demand. Consequently, even if an accumulated earnings tax was properly assessed against Taxpayer, which ' Taxpayer denies, Taxpayer is not liable for any interest on such tax.” “(7) Under either of the alternative conten- tions (5) or (6) stated above, Taxpayer is not liable for any interest on the accumulated earnings tax assessed against it for the tax- able year in question. Accordingly, even if an accumulated earnings tax was properly as- sessed against Taxpayer, which Taxpayer de- nies, the interest assessed against and paid by Taxpayer with respect to such tax con- stitutes an overpayment for which Taxpayer is entitled to a refund. 50 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION (Title Omitted in Printing) ANSWER (Filed July 15, 1971) The defendant, United States of America, by and through its attorney, for answer to the plaintiff's com- plaint herein, admits, denies and alleges as follows: 1. Admits the allegations contained in paragraph 1, ex- cept denies that the internal revenue taxes sought to be recovered herein were erroneously and illegally assessed against and collected from the plaintiff. 2. Admits the allegations contained in paragraph 2. 3. Admits the allegations contained in paragraph 3, ex- cept denies that the taxes referred to therein were er- roneously and illegally assessed against and collected from the taxpayer. 4. | ‘Admits the allegations contained in paragraph 4. 5. With respect to the allegations contained in paragraph 5, the defendant answers as follows: Denies the allegations contained in the first sentence and alleges that upon audit of the taxpayer’s returns for 51 the taxable.years in question, the Secretary of the Treasury or his delegate determined that the alleged salaries which the taxpayer paid Mr. Ivan Allen, Sr., and Mr. Ivan Allen, Jr., were not ordinary and necessary business expenses of the taxpayer. Admits the allegations contained in the second sen- tence. 6. Denies the allegations contained in paragraph 6, ex- cept admits that the Secretary of the Treasury or his delegate assessed against the taxpayer, for the years re- ferred to, additional income and accumulated earnings taxes, together with interest thereon, in at least the amounts set out in paragraph 6. 7. Admits the allegations contained in paragraph 7. 8. Admits the allegations contained in paragraph 8, ex- cept denies that no decision has been rendered on the said claims for refund, as amended, by the Secretary of the Treasury or his delegate. : 9. Admits the allegations contained in paragraph 9, ex- cept denies each and every allegation of fact and each and every contention set out in the claims for refund and amendments referred to in paragraph 9 unless other- wise specifically admitted herein. 10. Denies the allegations contained in paragraph 10. 52 11. Admits the allegations contained in paragraph 11, ex- cept denies that the taxes and ‘interest referred to therein were erroneously and illegally assessed against and col- lected from the taxpayer. 12. Denies the allegations contained in paragraph 12. 13. Admits the allegations contained in paragraph 13, ex- cept denies that the additional income and accumulated earnings taxes and the interest thereon sought to be re- covered herein were erroneously and illegally assessed against and collected from the taxpayer. 14. Admits the allegations contained in paragraph 14. WHEREFORE, the defendant prays for judgment in its favor, for dismissal of the plaintiff's complaint with prejudice, for costs and for such other and further relief as justice may require. The defendant requests a trial by jury. John W. Stokes, Jr. United States Attorney By: /s/ Stanley M. Baum Assistant United States Attorney (Certificate Omitted in Printing) 53 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION (Title Omitted in Printing) — STIPULATION (Filed June 12, 1972) The parties hereto through their respective counsel stipulate and agree as follows: ~ 1. This is a civil action instituted by Ivan Allen Com- pany (hereinafter referred to as the “taxpayer’’) against the United States (hereinafter referred to as the Govern- ment) for the recovery of $212,132.53 in federal income and accumulated earnings taxes, including interest thereon, paid for the fiscal years ended June 30, 1965 and June 30, 1966. 2. Both factual and legal issues are presented by ‘ the case. One of the legal issues (set out hereinbelow in paragraph 15) is such that its resolution may be disposi- tive of the taxpayer’s claim for the refund of the accumu- lated earnings taxes involved. Therefore, such issue is hereby submitted to the Court for decision. Pending the Court’s decision thereof, the remaining issues in the cage may, subject to the discretion of the Court, be held in abeyance. 3. The taxpayer is a Georgia corpcration engaged in the business of selling office furniture, equipment and such other supplies as are used in offices and places of business. ; 4. For its fiscal years ended June 30, 1965 and June 30, 1966, the taxpayer filed its federal income tax returns 54 with, and paid the tax shown as due thereon to, the Dis- trict Director of Internal Revenue, Atlanta, Georgia. True copies of said returns are attached hereto as Exhibits A and B, respectively. 5. Following an examination of the taxpayer’s fed- eral income tax returns for the fiscal years ended June 30, 1965 and June 30, 1966, the Commissioner of Internal Revenue determined, among other things, that the tax- payer had permitted its undistributed earnings and profits for each of such years to accumulate beyond the reasonable and reasonably anticipated needs of its business and that one of the purposes of the accumulation for each such year was avoiding income tax with respect to its shareholders. Based upon such determination, $77,383.98 and $73,131.87 in accumulated earnings taxes, together with interest there- on, were assessed against and collected from the taxpayer for its fiscal years ended June 30, 1965, and June 30, 1966, respectively. Thereafter, and within the time provided by law, the taxpayer duly filed claims for refund of such ac- cumulated earnings tax and interest. When the claims for refund were not allowed, the taxpayer instituted the in- stant action alleging that such accumulated earnings taxes and interest were erroneously and illegally assessed against and collected from it. 55 6. At the close of its fiscal years ended June 30, 1965 and June 30, 1966, the taxpayer owned listed and unlisted marketable securities the cost and fair market values (FMV) of which were as follows: 40 shs. Arlington Development Corp. common stock ~ (unlisted) 300 shs. C. & S. Capital Corp. common stock (listed) $600 Commerce and ~ Jackson County Development Corp. bond (unlisted) 149 shs. Minnesota Mining & Mfg. Co. common stock (listed) 165 shs. Southern Airways common stock (listed) 11,140 shs. Xerox Corp. common stock (listed) 10,090 shs. Xerox Corp. common stock (listed) $30,600.00 Xerox Corp. convertible debentures (listed) a (payable as capital gains taxes). FYE FYE Cos FMV Cost FMV $ 1,000$ 1,000 $ 1,000 $ 1,000 1,650 788 1,650 825 600 600 3,046 8,605 600 1,650 116,701 1,573,525 102,479 2,479,617 30,625 48,424 30,625 69,768 $154,222 $1,634,592 $135,754 $2,551,210 7. The cost of converting the taxpayer’s marketable securities into cash would have been the sum of a maximum of 6% of the fair market value of such securities (payable as a brokerage commission) and a maximum of 25% of such amount of the fair market value as exceeds the sum of the brokerage commission and the cost of the securities ae 56 8. For its fiscal year ended June 30, 1965, the tax- payer paid dividends to its stockholders as follows: Cash $48,945.30 870 shs. Xerox Corp. common stock (at cost) 6,564.34 9. For its fiscal year ended June 30, 1966, the tax- payer paid dividends to its stockholders as follows: Cash $50,267.49 10% stock dividend of Ivan Allen Company 10. In determining whether the accumulated earnings taxes involved herein were erroneously and illegally as- sessed against and collected from the taxpayer, it is nec- essary to determine whether the taxpayer’s undistributed “earnings and profits [were] permitted to accumulate be- yond the reasonable [and reasonably anticipated] needs of the business,” within the meaning of Section 533(a) of the Internal Revenue Code of 1954. 11. For the purposes of determining whether the tax- payer permitted its earnings and profits “to, accumulate be- yond the reasonable [and reasonably anticipated] needs of the business,” within the meaning of Section 533(a) of the Internal Revenue Code of 1954, the parties agree that the taxpayer had reasonable business needs for operat- ing capital equal to $1,198,309.00 and $1,455,222.00 at the close of its fiscal years ended June 30, 1965 and June 30, 1966, respectively. 12. The amounts of net liquid assets (current assets less current liabilities) owned by the taxpayer at the close of its fiscal years ended June 30, 1965 and June 30, 1966, were $1,198,309.00 and $1,455,222.00, respectively, if its marketable securities are taken into account at cost, and + $2,235,029.00 and $3,152,009.00, respectively, if its market- able securities are taken into account at their fair market value less the cost of converting them into cash. ee 57 13. If, in determining the amount of the taxpayer’s net liquid assets at the close of each of the suit years, for purposes of determining the applicability of Section 533 (a) of the Internal Revenue Code of 1954, the taxpayer’s mar- ketable securities should properly be taken into account at cost, the taxpayer’s undistributed earnings and profits were not permitted to accumulate beyond the reasonable and reasonably anticipated needs of the taxpayer’s business. 14. If, in determining the amount of the taxpayer’s net liquid assets at the close of each of the suit years, for purposes of determining the applicability of Section 533 (a) of the Internal Revenue Code of 1954, the taxpayer’s mar- ketable securities should properly be taken into account at their fair market value (less the cost of converting them into cash), the taxpayer’s undistributed earnings and profits for each of such years were permitted to accumulate beyond the reasonable and reasonably anticipated needs of the taxpayer’s business. 15. Thus, the following legal question is presented for resolution by the Court: Whether, in determining the amount of the tax- payer’s net liquid assets at the close of each of the suit years, for purposes of determining the applicabil- ity of Section 533(a) of the Internal Revenue Code of 1954, the taxpayer’s marketable securities should properly be taken into account at their cost, as the taxpayer contends, or at their fair market value (less the cost of converting them into cash), as the Gov- ernment contends. 16. In the event it is determined that the taxpayer permitted its undistributed earnings and profits to ac- cumulate beyond the reasonable and reasonably anticipated needs of its business, a further factual issue relating to the 58 accumulated earnings tax involved in the case remains to be resolved, ie. whether one of the purposes of such ac- cumulations was avoiding income tax with respect to the taxpayer’s shareholders. In the further proceeding, if any, to resolve said remaining factual issue, either party may, subject to pertinent objections, offer any evidence therein which is not inconsistent with the matters stipu- lated herein. June 12, 1972 /s/ Kirk McAlpin Date Counsel for Plaintiff June 12, 1972 /s/ Jack D. Warren Date Counsel for Defendant — 59 Exhibit A ees TS me, leet ng atin ie 41% ' rout 2IABE 9S. » oth BitsA7: ise He BER we LAX RE: al—ifd4 92471579 ia dbp at her gp pny of ether tasabie year bepaceng on SUL -accce nk on bee MOE Te EL y--- -W.£5 ISI REESE o— ‘ous fi : E. Explover bies..ticat.cn No. * pecan, ans jyan2cc2s co Paty 1565 co SE 6 58-01 36520 o eS on ROX 1712 5. County in which tc -o%o¢. & Fers-oci felting CoO ATLATTA Ca 3022} fy O55 Toss ncwscue ©. 5 - $2.77 — 18 HAPORTANT—All applicable lines and schedules must be filled in. If the lines on the schedules cre not sufficient, see instructi 1. Gross receipts or gross sales catebeinsssnnenceennernonTe Less: Ret: and al! 2, 501, aa ts ¥ 62 | 2. Lees: Cost of goods scld (Schedule A) and/or operations (attach schedule)........+--2.0eeereeeeeees 10 571.01 ee Oe I is so occ scopphceboccanesens rates oo ewahece pacer pendinneeCs ana enee 30 ak ‘ye Be Ee IR sihicissstrssietnsnsssessmpniasdieetbesecorornannercivveviseredlipnéiions 59,293.63 & 5. Interest on obligations cf the United States and U.S. snitvenieiialiies ikesuaawienen Lcacksdsadenciouse oes sey ba enbacsenoccarser® py ge pene eres ain FEES 43,203.26... a EE cevovccccnscvesoocees Side ch edewovereesseava bhbsenedarvapanckedwnl +esi nie khee kanes ee 159,325.76 GPE Be BepRGS oon cc cccccccdcccececcccdcccccccnscesccsccccesccvercceversiuceseerensovevccovees & ik ales Gee Seas Seni Mibadiie®. «025.0050 0.0 (é) . Losses by fire, storm, shipwreck, or other casualty, or theft (attach schedule)..........0.scecererereres Ea 2 I BI AI tress pepe ckss sas ij nesconsvapsasestndncasssarndssdewasieteraiens £ 22. Depreciation (Schedule G).......... ‘egsesvanesvbapeeme pr edenveeven peqececcoes deneeneneeeeenetes aA SB. Depletion Glades sche. oi os ccs cc ccccncsceccvccesevedscoscesveveessevvdscee dca cupaniebsevane BA | 24. Advertising .........cecececccceccrecseeecsrecssscecsserstsrcetseneasssreteseeeeseeenenesenes @ | 25. (a) Pension, profit-shating, stock bonus, anmgtz,p\ Tre Se BORG ey SPAT maN ete AS ERSES.. 1000 «00 Seas (b) Other employee benefit pions”? 3- “pstreetions) Se Peas ROLES hb bis tte PME a aR bee ee ote 26. Other deductions (attach schedule cakmueas ween teks auger beset ° cuss oes audedaees cea wenes ree SH 21, TOTAL deductions in ines «oo BE 15, IS35......... ISG MEE ask BR 2,009 ,013.2 28. Taxabie income before net operating IDa Potptigp 907-7 deductions (line ! 1 less line 27)......... 391 4b5 41 29. Less: (a) Net operating lors deduction (see ingtpyct Rate schedule). . i (b) Special deductions (Schedule ! DepiiaR = gg Bis. 50.399. 22 ee: Sees Seen Cie Te AOU re occ seer chbd chcce cekschenieto ck cedie bebe ve ki wateee 341, O45.52 31. ESTAS, seme tae Wels Wand 00 Saale Ofc os ns vcs owe cde or bck ape> gas Consaas cos 160.335. 32. Credits: (a) Tax paid with Ferm 7004 application for extexsion (attach copy)... f , (b) Payments and credits on 1964 declaraticn of estirncted tax......... 4 ' (c) Credit from regulated invest nent comrenies (c't2ch Fem 243%. 106,020.00 i DUE. Enter beiarce heze > 54 310.95 33. If tax Gine 31) is larger than credits (line 32), the balance is TAX D 34. If tax Cine 31! is less than c-edits (ire 32) | 25. Ester emount of line 34 you went: Credited on 1265 es.inioted tex - Reiunded . Eviter tho OVERPAYMENT here ——-——> tue cesi cl my arcwledge ord Ciel it ig true, correct, ord ccmrlete. Under pencities cf cerjury, 1 ceciare tnat I have excinine? this return. im a ing schecules oe fictements, —s te If crepe cacil denna ct which he bas cny srowledge. red by o pericn cther ther toxpover, his decleraticn is besed i» i peeeens Ny i/S2 C0 SE RPTE Fibre] oy “ él tA, -' . Bie dt Fresite.:| ius Bate “"""Signeture cl ckicor Tide : Gubracy, AWRINCE & HORTDI ‘ CEINNED PUsu.c ATCCUNTAYTS a See eas Kcisadad coi os canae rok enone BUC ts Wee Ndi ee ——--+ 5 eC --16—722 2 Torn 1120 0964) Schedule A.—CCST OF GOODS SOL (See instruction 2) | 1. Was taventory valy &—Coct 0 lower A on Or market Eb (Where inventor” are an incom de:. “mien factor) | - LIFOC) ether 2)?» ether, ettach explana se a ura meal = 2. od pony ae bren made to inve. tory? Wes i wO lt 1. Inventory ot beginning of year............ 5 9405537.61 anne pew enh pompated on tho vee 2. Merchandise bought for menufacture or sale.| 3,2 So oe : s Spascetne petadiade ie om the te‘al iaventory 3. Solaries and wases...... pp caitesecciions 2, 7h1.81 : fen individual items. —_ « pa if “a’ ">" pp pcted. gute the percentage of write- 4 Other costs per books (attach schedule).....|Ti2, 22.43 jh Nh ¢ = ‘a’ enter the dollar ‘omouni of wrile-downs $.. 21,324 51 “alan orsdette 079 BS 25 estimate that the figure is an esti nate CD encbiocniaccassacdeapachapuieors nes 52079 sT 3. Was the inventory ver:fied by es count during che year? Yes EZ) No It attach explanation was 6. Less: Inventory at end of ysar............. 569,214.25] « ney Beto substantial change in he ft don 1. Cost of sold (enter here and on lire 2, : ven the opening a: osing in bf No if “Yes,” attach * ad erent eee 4 .530,57].08| som Radettenn euedicamensenan Eka Scheduie C.—INCOME FROM DIVIDENDS © Geneetie 3. Cortass proterred &. Memeo) Gectestafeanyeretes tasadie under 1, Her 4. Foreign corpeeat.as| $. Qther corporation, ee ee akeidbeswliuieiesswcbidsoci a ; Total of columns 2, 3, 4, and 5.............. chindivekonkouheentie dado + tpeneccccarcsesecsccesseescerereslssessecerereccsccenvece fee a holder of ie poration (attach stat De pivtisvbkedesednncee otal (enter here and on line 4. page |) ........). :. Schedule : a i 159,293 63 Soi b D.—Separate Schedule D (Form 1120) should be used in reporting soles or exchanges of property. (Gee instruct n 9 Schedule E.—COMPENSATION OF OFFICERS (See page 5 of instructions) 1. Time Ge- | Percent of corporation L Mame and address of officer ssleerssomend voted to Stochownes * 6. Amount of ¥. Gagenee omenee T 7 CEE CRRReRIoEe aRRCER WEIR mae me seme - / i Total compensation of officers (enter here and on line 12, page 1)........... 06sec eee ceveeee aiden 2. Schedule F.—BAD DEBTS—RESERVE METHOD ¥ , 2. Trade notes and accounts re- Cor adie outs Landong 4. Gross amount added to at ond of year reserve : 1. Seip on senses 6. Reserve for bad Cebdts at end of year / rE (I Baas cabianciis die taastit cee Badd io aaa o oa Eee , Schedule G.—DEPRECIATION (See instruction 22) This schedule is designed for taxpayers usirg +. a! eeatine —, and admiristrative procedures described in 62-21 as well as for those taxpayers who vish es authorized prion to the Revere P. appeor use the first ng Aer Sin tad eeaatied oad he eden toadan erie dee aneaden Revenue Procedure rocedure. Where deuble 2. Gost or other basis | 3. Asset diiaia salmaaa 6 tenes ae oon ene et oe Gules ees antes Liked Fak woe? wpasgend * ayes toneeat eee of tm ap © Copenaien tx "(Description of property Cost oF otner wcaures | Geena hy so pres yous | Songun, | ei” - 4 ‘ 1. Total additional first yer depreciation (do not include in items below) TRO OeHOHE EEE EHH EH EEE EEEEEE EEE HEE EEE EEE EEEEEEEEEESD | US. TREASURY DEPAZTMENT—INTERKAL REVENUE SEZVICE '. rom 1054 APPLICATIO;: F°? AUTOUATIC EXTESION OF TWF 7O FILE US. Cor? ORATION _ Rew. Fo. 1999 CGE TA. aETURN (SEC. 6231(b), UITERSAL ..cVESIUE-CODE OF 1654) | (See Instructions on reverse side) For taxable year beginning ............ duly 1, 194 and ending 7 June 30, 000 19.65 PLEASE TYPE OR PRINT PLAINLY DO NOT WRITE IN | Wome of corporaucn SPACE BELOW If an exiexsion of time is = necessory, file this form with Senel IVAN ALLEN the District Director of In- | pases COMPANY ternal Revenue on or belore the iSth day of the third j BOX 1712 month following the close ot Car oF town, postal sone humber, State the taxable year. ° ATLANTA, GEORGIA 30301 Application is hereby made for an automatic extension of three months for filing the completed return of the corporation named herein in accordance with the provisions of section 6061 (d) of the Internal Revenue Code of 1954. A remittance of dn amount not less than would be required as the first installment of the tax ly oi d to be due for the taxable year shown above accompanies,this application. 1. Tentative amount of tox for the taxable year......... 66. cece cece receeecee $ 166,020.00 2. Less: Payments made on declaration of estimated tox... 0.0.06. eee ceeeeeeee s......46,020.00 BD, BRON GOD sec cccsccesvisessorcasccvsswocscccesccsoseccucen asvoeseses $....120,000.00 4. Amount of remitiance.....00 0.66 cece e cede cece ese eneenceeeeeeeeunees $ 60,000.00 SIGNATURE AND VERIFICATION I declare under the penalties of perjury that I have been authorized by the above-named corporation to make this application and the. to the best of my knowledge and belief the statements mdde herein are true and correct. Pear enecese eee eneees §— eaneewesennesenererneers entee ereneeesesesenssase-sene PO OOO erecerenes serererecececerescseaesoereseresesesseees (Signoture—see instructions) (Tide. df an ofi.cer of the corporation) ate) I declare under the penc!ties of perjury that 1 am currently enrolled to practice before the Trea. ry Department and have been authorized by the above-named corporaticn :o moke this application; and that to the best of my knowledge and belief the statements made herein are true and correct. 4 A COPY OF THIS APPLICATION MUST BE FILED WITH THE TAXPAYER'S COMPLETED RE” URN é —- SCHECULE D US. Treasury Departrert internat Revenue Service (Form 112) | GAINS AND LOSSES FROLI°SALES OR EXCHAWGES OF property | 1964 Name and address IVAN ALLEN COMPANY - ATLANTA, GEORGIA PART I.—GAIN FROM DISPOSITION OF DEPRECIABLE PROPERTY UNDER SECTIONS 1245 #.ND 1250—Assets Held More Than 6 Months-—Where double headings appear, use the first heading for section 1245 and the secon’ heading for section 1250. . Cost or other basis, cost of & Kind of property (it necessary, attac> statement of ® Date acquired ¢ Date ssid | 4 Gen ete . ak eapeoeenoun OF descriptive detaris aot shown Deiow (me, day. yt.) (mo., Gay, yt.) | = Ration) and expense of sale “ES... NU, eee = t. Depreciation allowed (oF ailowadle) sinc’ acquisition | « schedule Ordena: goin, January Decemder e es sum of nh] 1-2) yy ‘Sa = ae ——- amc ee Gueabains Prior to January 1, 1964 After December 31, 1963 ~ a 2. Total ordinary gain. Enter here and on line !! and identify as gain from Part! ...... 3. Total other gain. Enter here and on line 4 and identify as gain from Part]... 0... oe cece cece cee PART II.—SALE OR EXCHANGE OF PROPERTY UNDER SECTION 1231 @. Depreciation allowed! {Cast or other basis & King of property (it necessary, attach statement |b Date acquired | ¢. Date sold | 4 Gross sates price | (OF allowable) mince | coal auberquentim: | ¢. Gain or loss Of descriptive detais not shown delow) (mo, Gay, yt.) | (imo. day, yt.) contd | ghaned attach explana. (4 plus e less f) Won) and expense cf sale RE SOR RE Oeak oi: eatin’ | 4 8. Total (If gain. enter on line 9: if loss. enter on line 11. Identify as gain or loss from Part I.).................... ‘ PART III.—CAPITAL ASSETS Short-Term Copital Gains and Losses—Assets Held Not More Than 6 Months WW cides piscine tala eimai aliinencteiiadaaiscanal chbda cast 5 Wiis tena onc ents igs ledge toieiuloaisAaleis tion Siva cc ecinesD be eaiiasanilibaiaangiaitns Rouhae-cltagubulatanss; Miviiesion tT! 2. ‘Qeund caged loss carryover tottcch danni. rte x stele sk WO A NUS Ua WSS a TRAD AL WEE aca uu er oee 8. Total of short term capital gains or .osses or ditterence between short-term nna gains cnd losses. eR —In the case of @ sale or exchance, directly or indirectly, 0: property between aa — and a corporation more than 50 percent in value of the standing siock of which is owned by sch indivi his spouse, oa ais minor children and en pl sandccniidren, any gain receg- nized to the transferor from such or exchenge shall be treated as gain from the sale or exchange of preex ty which is neither a capital asset nor described in section 1231, if sucn prop- ene on eenentee & Sepenctale under section Installment sa!c3.—=: ou sold persona! ao $1,0C0 or recl propesty Fesardiess of omour. me tire y be etig: to report any gcir. Under te installment pian ea tesa ne ment in the yecr o! sale, or (2) the payments in the year of sale =r not exceed of the selling price. Section 453. For treatment of a portion of payments as “unstated intere:t”’ on dei: ted payment sales, see section.483. (Instructions sees on reverse of duplicate) CLEARING HOUSE. INC., CHICAGO, NEW TORK. WASHINGTON. 65 COST OF GOODS MANUFACTURED ~ IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1965 Quick- 3 copy Printing Inventory - materials, June 30, 1964 $ 3,97%.10 $ 68,702.95 Purchases - materials 2,499.84 523,110.08 Freight 7-55 32991 75 #62 49 595,004.07! Less inventory - materials, June 30, 1965 498.3 65,1 MATERIALS USED Direct labor Manufacturing expenses: Labor - indirect Payroll taxes Rent - building - equipment Heat, power and water Depreciation, equipmer:t Insurance Taxes, general Maintenance - equipment Supplies - depar:=menta > - litho - letterpress - composition - cutting machines - bindery “EB” - plate making 7,292.79 7,732.01 - collator - 1,930.71 - rotary press - 940.48 - camera - 2,990.40 Outside services 2,207.38 23,741.80 Other . 2,047.90 1,800.97 TOTAL MANUFACTURING EXFENSE 3 29.555.08 $ 202.045.00 _$ TOTAL COST OF GOODS MANUFACTURED $252.592.77 $1,045,195 46 66 TAX SCHEDULE - 58-0136820 IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1965 DIVIDENDS Xerox $ 5 3 M Company Ivan Allen Company of Huntsville 2 Ivan Allen Company of Augusta 4 Ivan Allen Company of Athens, Tenn. 4 Southern Airways Ivan Allen Company of Gainesville 5,8 1 14 11 J \o wy uJ ie) 38 QBS888ssAw / Ivan Allen Company of Columbus Ivan Allen Company of Rome Ivan Allen Company of Macon Ivan Allen Company of Greenville i OTHER INCOME Discount’ earned $ 77,074.94 Sales tax compensation 214.52 Profit on special sales 6,557.19 Purchase charges to subsidiaries 92,440.76 $176 2 287 41 COMPENSATION OF OFFICERS Compensation enses Ivan E. Allen, Chairman 12,525.1 960. W. H. Glenn, Jr., President 31,025.00 1,919.89 H. C. Jones, Exec. Vice-President 27,524.92 2,039.95 W. F. Floyd, Jr., Sec.-Treas. 21,224.92 706.47 J. H. Carnes, Vice-President 22,159.32 706. 30 W. D. Harris, Vice-President : 24,824.92 860.57 J. N. Murphy, Vice-President 17,024:92 3,423.05 $156,309.16 f : ne > ee TAX SCHEDULE - 58-0136820 IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1965 OTHER DEDUCTIONS Travel and entertainment $ 54,895.25 Telephone and telegraph ‘33,932.67 Postage 18,116.77 ‘Dues and subscriptions: 19,438.35 Sales promotion 4,968.15 Stationery and supplies 45,950.23 Heat, power and water 16,973.23 Truck 21,165.60 Amortization, leaseholds 3,267.00 Insurance 23,581.98 \ Employees welfare 3,922.68 \ Administrative charges to subsidiaries (56,100.00) \Legal and professional 10,629.13 Credits and collections 1,702.68 Bank charges 685.42 Contract services 12,778.30 Directors fees 1,700.00 Rent commissions 2,875.08 Pensions 2,808.60 Miscellaneous 20 ,822.82 $244,113.94 QUESTION I (1) FEDERAL RETURN Ivan Allen Company of Albeny, Ga. 96.00% Ivan Allen Company of Athens, Ga. 100.00 Ivan Allen Co. of Athens, Tern. -67 Ivan Allen Co. of Augusta, Ga. -67 Ivan Allien Co. of Chattanooga, Tenn. 100.00 Ivan Allen Co. of Columbus, Ga. 67 Ivan Allén Co. of Gainesville, Ga. 90.00 Ivan Alleh Co. of Greenville, S. C. 60.00 Ivan Allen Co. of Huntsville, Ala. 100.90 Ivan Allen\ Co. of Macon, Ga. 66.67 Ivan Allen\Co. of Rome, Ge. 96.7 ose - ace 68 TAX SCHEDULE - 58-0136820 IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1965 TAXES City, state and county $43, 323.82 Intangibles 1,643.19 Domestic corporation 1,000.00 Corporation registration 2.00 Business licenses 943.00 Automobile and truck 229.50 6,896.58 Pay roll 49,755.07 $ 96,896.5 Less taxes charged to cost of sales 13,854.32 GEORGIA 3,042. Georgia income tax - current years $17,683.57 - prior years 2,676.50 20,360.07 $103 2 402. 33 CONTRIBUTIONS : Atlanta Humane Society $ Georgia Cumberland Conference Exchange Club Oglethorpe Boucters Club Marion Howard School Junior League Florence Crittenton School Enpty Stocking Fund. Buckhead Lions (lub North Fulton Fine Arts Foundation Christian City Salvation Army Allen Foundation: Cash $10,000.00 100 shares Xerox Corporation - cost 2-24-61 $641.98, fair market value 1-29-65 10,800.00 20,800.00 $ 22,261.45 1,659.10 ~ in ZuaSyse = S8RsS 883883838s8E8888 Less contributions carryover - federal CONTRIBUTIONS - FEDERAL $ 20,602. 38 69 TAX SCHEDULE - 58-0136820 IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1965 BALANCE SHEETS 6-30-64 6-30-65 Other investments: Marketable securities \ $161,428.56 $154,222.25 Investments in subsidiaries _ 318,525.55 351,141.38 $479,954.11 $505,363.62 Other assets: Cash value of life insurance . $162,645.52 $176,864.5¢ Prepaid expenses 39,695.35 28,811.61 Leasehold improvements - net 23,096.13 19,829.13 \ 437.00 $225,505.33 Other current liabilities: Income taxes $180,752.36 $151,521.21 Other taxes 76,274.09 89,819.67 Accrued salaries and weges 10,037.53 16,557.54 Accrued interest 432.67 41k. 69 Accrued profit sharing pension contribution 59,257.06 59,786.76 £6,753. 8,099. 70 STATEMENT OF RETAINED EARNINGS IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1965 Retained earnings, June 30, 1954 $1,997,242.28 Add: Net income for the year ended June 30, 1965 232,584.98 Excess of fair market value over cost of 100 shares Xerox Corp. stock donated to Allen Foundation: Fair market value 1-29-65 $10,800.00 Cost 641.98 10,158.02 Reverue Agent's adjustments for F.Y.E. 6-30-63 and 6-30-64: Capitalization of essets previously charged to expense $43,696.22 Reduction in sllowable depreciation 685.58 Reversal of accrual of contribution to ’ Allen Foundation not timely paid 7,500.00 51,881.70 294 624.70 $2,291, 866.98 Deduct: Prior years' income taxes: _ Federal $33,496.07 Georgia 2,676.50 $ 36,172.57 Dividends paid: Cesh $48,955.30 870 shares Xerox Co. stock - at cost 6,564.34 55,509.64 91,682.21 RETA1..ED EARNINGS - JUNE 30, 1965 $2,200,184.77 i hy 71 STATEMENT OF PROPERTY PLANT AND EQUIPMENT IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1965 bY ate cree 4 a Uf, . teats cae fr KE 2, /. auld 6 oer up La , / , (4 - FEL 6. ee / te, we “ae ais ses ye PP pane vo, /7as 2 Ser See seers Sess rc set seser sees seecs Fr e444 Fit Pt we === + +4 Assets Allowance for depreciation Cost less Balance Balance Balance Balance depreciation Jun. 30,1964 Additions Disposals Jun.30,1965 Jun.30,1964 Provision Deduction Jun.30,1965 Jun.30,1965 Rental property: Land : 972 Marietta st. $ 35,250.00 $ - $ - $ 35,250.00 $ ono - $ - $ - $ 35,250.00 1740 Peachtree St. 120 ,000.00 - 120,000.00 o - “ _ 120,000.00 221 Ivy Sst. 74,000.00(C) 76,000. 500 - 150,000.00 - @ - o 150,000.00 660 Forrest Road 72,000.00 - - 72,000.00 - - - a 72,000.00 Buildings: 972 Mariette st. L. 1948 - 34 81 997-69 - - 81,997.69 39,768.85 2,459.93 - 42,228.78 39,768.91 Improvements: Sprinkler - 1948 - 5% . 9,937.00 - - 9,937.00 7,436.16 496.85 - 7,933.01 2,003.99 Roof - 1955 - 10% 4,097.84 - =. 4,097.84 3,892.91 204.93 - 4,097.84 - 1740 Peachtree St.: 1959 - 5% - (A) 183,078.48 Ps - 183,078.48 44,957.41, 6,906.05 - 51,863.46 131,215.02 Improvements - 1959 - (A): Elevator - 10% 15,500.00 - 15,500.00 6,805.02 869.50 - 7,674.52 © 7,825.48 Blacktop - 13.3% 6,900.00 - - 6,900.00 3,747.42 419.29 - 4,166.71 2,733.29 Electrical - 13.3% 31,000.00 - 31,000.00 16,831.40 1,884.42 o/ . 18,715.82 12,284.18 Plumbing, heating and / _ air-conditioning - 13.3% 63,000.00 - - 63,000.00 34,105.73 3,842.94 - 37,948.67 25,051.33 Carpets, etc. - 20% 9,000.00 - - 9,000.00 6,345.79 530.84 ats 6,876.63 2,123.37 221 Ivy St.: ' 1960 - 44 177,012.25(C) (76,000.00) - 101,012.25 24,781.72 spe 6,300.84 22,521.37 78,490.88 1963 addition - 44% 428,754.03(C) 16,011.11 ~ 4d, 765.16 25,725.24 17,790.61(c) (1,189.02 4h, 704.87 400,060.27 1963 roof - 5% - (c) 8,156.00 - 8,156.00 - 407.80(C (407. 80 815.60 7,340.40 1963 waterproofing and eS : sign 20% - (Cc) 9,190.54 “* 9,190.54 - 1,838.10(c) (2,103.67) 3,941.77 5,248.77 660 Forrest Road: . 1964 - 5% = (A) 121,058.94(c 00.00 124,558.94 EAE 95 S, 227. 5 ne 1330- 99 2 3 95 a 3 bye 5 $ red 2 2 36 Furniture and fixtures: Store - 1961-2 25% (A) $. 2h9.2k $ - $ - $ 249.2h $ .i1gh.12.$ 31:98 - $ 155.40 $ 93.84 - 1962-3 25% * 161.41 - ~ 161.41 55.49 26.48 - 1.97 Plant - 1958 20% (A §36e-T8 - - 3,562.74 2,722.18 - Office - 1956 20% (A 4,736.12 - - 4,736.12 4,020.98 va = 1957 -20% (A 88 : 388. 314.82 - 1959 204 (A 10,746.29 - 1,955.50 2,790.79 8,210.92 - 1961 20% (A 3,675.00 - 3,675.00 1,981. 56 ~ 1962 25% (A 1,673.01 - - 1,673.01 833.13 - 1964 254% c 3,960.00 - - 3,960.00 495.00 - 1965 25% (B - 7,439. - 7,439.50 71526 ° 72 STATEMENT OF PORPERTY PLANT AND EQIUPMENT - CONTINUED IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1965 ' ' I . oo 2 | ag Assets Allowance for depreciation Cost less Phage a Pg ‘ Pa mir Balence depreciatione .30, po -30, in. 30,1964 Provision Disposals Jun. 30,1965 Jun. 30,1965 jutomobiles and trucks: sete . | *ig6l Paton - 66 2/36 (A) $ 1,606.78 $ 4 $ 1,606.78 $1,4 1961 Falcon - 66 2/34 (A 1,606. - - p06. 1,472.68 $ 89.25 - 1,562. 1962 Chevrolet - 2 2/3% (A) 3,471.22 - - 3,471.22 2,699.84 514.50 , - , tA ’ Pag 1964 Oldsmobile - 33 1/3% | 3,114.68 - - 3,114.68 1,048.22 1,028.22 « 2,076. bi 1,038. 2h 1964 Chevrolet - 33 1/3% 2,999.11 - - + 2,999.11 498.18 999.70 - 1,497.88 1,501.23 1964 Cadillac 5,706.21 - 5 4706.21 - 951.03 - 951.03 ‘ ona 1964 Ford Mustea 3,281.24 - 3,261.24 - 546.82 - 546.82 ‘* ‘ 1965 Cadillac - 33 1/3% - 6,581.09 , = 6,581.09 - 2,193.70 - 2,193.70 4,387.39 | Sede Gaui soe ~ 908 ( ‘-atn.23 és 1962 Chevrolet panel - 66 2/3% 2062.21 - 2,062.21 ' ~ 1,604.39 - 1,604.39 ee ra 1962 Chevrolet panel - 66 2/3% 1,682.13 - oer 1,682.13 1,308.70 248.85 va 1,557.55 124.58 1963 Ford van - 66 2/34 (A) 2,012.33. ‘ .- - 2,012.38 1,565.63 298.00 - 1,363.63 148.75 1964 Chevrolet panel ~ 33 1/3% 1,868.96 - - 1,868. 311.55 623.00 « 934.55 934.41 1964 Ford van - 33 1/3% © 2,054.75 - 2,054.75 - 342.45 - 342.45 1,712.30 1965 Chevrolet panel - 33 1/3% - 2,358.31 - 2,358.31 - 373.05 - 373.05 1,985.26 1965 Chevrolet panel - 33 1/3% + 2,168.93 - 2,168.93 - 361.50 - 361.50 1,807.43 1965 Chevrolet panel - 33 1/3% - . 1,636.34 ° 1,836.34 . 306.06 - 306.06 1,530.28 Quick -Copy depa:rtment : . é 1965 Ford - 33 1/3% 92-00 1,160.00 / p { — ON arate eee STATEMENT OF PROPERTY PLANT AND EQUIPMENT =-CONTINUED =. IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1965 on pees " Assets Allowance for depreciation Cost less Balance Balance Balance Balance depreciation Hl Jun. 30,1964 Additions Disposals Jun. 30,1965 » Jun. 30,1964 Provision Disposals Jun.30,1965 . Jun.30,1965 potasey and equipment: inting plant: , 6 1/44: > 19h6 $ 295.00 $ - $ 295.00 $ - $ 285.82 $ 9.18 $ 295.00 $ tee - } 19h7 11,899.60 - - 11,899.60 11,699.60 - - 11,699.60 200.00 } -19h7 29,000.00 -. - 29,000.00 28,500.00 - _ 28 ,500.00 500.00 gh 7,200.00 - 7,200.00 - 7,038.00 162.00 7,200.00 - - / 1950 455.00 = = 455.00 412.38 28.44 - 440,82 14.18 worn) 12,875.20 - - 12,875.20 10,863.45 804.70 - 11,668.15 1,207.05 : 1954 42,135.00 ~ - 42,135.00 37,836.99 859.60 - 38,696.59 3,438.41 1956 16,600.00 - - 16, 600.00 14,093.38 501.32 - 14,59h. 70 2,005.30 1957 3,858.00 - - 3,858. 00 3,129.82 145.64 - 3,275.46 582.54 | 1958 26,527. 99 - - 26,527.99 20, 269.2 : io 75 - 21,520.99 5,007.00 | 1961 10,225.00 - 10,225.00 4,335.40 7-92 5,513.32 711.68 | 1963 35,550.18(C) 6 1838. 47 - 42,388.65 8,756.79 67313. 42(c)(1,914. 77) 17,014.98 25,373.67 ' 1964 38, 14.50 - 38,414.50 5,641.45 6,554.61 12,196.06 26,218. 44 1965 - (B) - 9,012. -50 - 9,012.50 - 1,362.14 - 1,362.14 7,650.36 EF i department: ~. - ne \ i 2,687.18 - - 2,687.18 2,179.99 101.44 - 2,281.43 405.75 | se 3,173.42 - - 3,173.42 2,694.24 95.83 - 2,790.07 383.35 1957 — 1,372.00 “ - 1,372.00 1,113.04 51.79 - 1,164.83 207.17 1958 ee 2,856.74 - ~ 2 +856 74 182.74 - 2 FU Tan-BL GIS B50.97 $7,095.00 8 253,080.78 ia $1,761 ,833=20__ $78,501.64 32,778.82 $1,807,555.92 Additional first year depreciation taken on first $10,000.00. 3 Declining balance method R.A.R. adjustments 85,614.8 21,941. Se oS - COPY BOUND CLOSE IN CENTER 75 \ on 1120 (19€4) Pace 3 Schedule I.——-SPECIAL DEDUCTIONS (Small busi : ’ ‘ panies and bers off affiliated groups not filing a consolidated return—see instructions) Dividends-received: (a) 85 percent of column 2, Schedule Co-+ +++ eee eeeeeee ese neeeceeeeee a ererirerit tis) 50,399.59. (b) 61:2 percent of cclumn 3, Schedule ¢C (cee instructions for fiscal year) ........ 62... eee ecb ceeeeceececeeennceenecee () 85 t of dividends received from™ certain foreign corporations....................5 Total dividend rink gs ey (sur of lines Too), (bd, annd (c) but not to exceed 85 percent of the excess of line 28, page | over line 4,of this schedule). (The 85-perce’ent limitation does not apply to a year in which a net ESOS, ROR Oey. yp eet enn eee ey LUTTE ee ee PLT ee Cee TTC TES Te Cer Cee eee 50.,399..59.. Dividends paid on certain preferred stock of public utilities (see® instructicns in case of net operating loss or fiscal year) «| _o........e ee eeeeeees Western Hemisphere trade corporations (not allowable in ye®t of net operating loss—see inst. for fiscal year)..... i sshcajuindilsioeeasas Total special deductions—Add lines 2, 3, and 4. Enter herd Gnd on line 2%b), page 1............ Seer, 50,399.59 , SCHEDULE jJ.—TAX COMPUTATION / (Component ial trolled co®rporate group use Form 3920 to compute your tax) f. » Taxable income (line 30, page 1)....... 22.2.2 ccc tt ttt tet e ee tees owéshens pikbasuans shane anue is soesinaaacinicanitabaniibis . If amount of line 1 is: ee ES Ge Ee TEST Tete eer TTT re ee ee eee eo (b) Over $25,000—Enter 50 percent of line 1... 2... ccc e eee c ee eeeee sees cee pbvad ee ; Subtract $7,000 and enter difference............e0¢t ctr tt ect e terre eens 7 OO I bins Income tax (line 2, or line 22 of separate Schedule D, whicthever is lesser, or fiscal year tax computation) Siekee ee 61,4 10. 59. Foreign tax credit (attach Form 1118)................... Balance (line 3 less line 4)....... cic ehatebesewwhuaenes Investment credit (attach Form 3468)...........-........ Balance of income tax (line 5 less line 6)................ Tax under section 541 of the Internal Revenue Code (from gSchedule SEER si hEs bc EERE a wkbas Rohen hohe a Tax from recomputing prior year investment credit (attach ‘ statement) heh ENDO Odd ME Oh Peake ee ehh bes babhbhhew }. Total taz—Add lines 7, 8, and 9, Enter here and on ling®_3!. page 1....................................- 160, 338.95 : (Fiscal year tax putati hedulde for t pay with t ble i over $25,000) T faxable income (line 30, page .)................ a Os Oey i ey Ce Cure als pu el enetnper + 3 percent of line 1........... RUS be be as oc Pee wewmecsu Ty USE t et Cee we Rese eee ahs + Subtract $7,000 and enter difference. ............... ccc ttt ttn tenets eee ence eee 7,000.00 MD ONIN EAN Bio eas os Sess Ukic oe eS nk we Fe PARA N ON Ra vee awe eines Subtract $6,500 and enter difference... 0.6... ee ete ete eens 6,500.00 Amount on line 2 or alternative tax (separate Schedule D) mnultiplied by the number of days in the taxable year prior to January 1, 1965, divided by the total number of d@aysan the taxable year... 26... eee eee ee fee 82,980.79. Amount on line 3 or alternative tax (separate Schedule multiplied by the number of days in the taxable year ' after December 31, 1964, divided by the total number of adays in the taxable year... 2.6... 0s sees sees eee ranean Income tax—Add lines 4 and 5. Enter here and on line 3, Schedule J» 161,490.59 \ Date incorporated ................--- 12-5-02 eer | ™. Did you by cone = deduction for expenses tonnected with: + (1) Did the corporation at the end of the taxable year own df pote. © Penni bn oy ferenonrm pomp abuey geen po pr ohare ipane 50 percent or more of the voting stoce similar facility (J? (Other than where the operation cf the Poa a estic corporation?.....%...... Yes &} No [' facility was the principal business.) Yes (1) No & 1) Moialion af the end of the lossole yesrowen anrecly oe FP Fen ge ae moe ype ge =. 50 percent or more of the corperation’s a used by customers or employees or bers of their tamilies? (For rules of attribution. see section 267 (o) 2 . (Cther than use by employees while in business travei status.) If the answer to (1) or (2) is “Yes,” attach separatite Yes No §) schedule showing: : (3) The attendance of your employees’ families at con- pao ty rye se and tara identification no?“ — 4 es meetings? Yes () a See tcentage ow i cat Fr empleo ne . ir for f = caswer to ) at sve i Bh mag Ly pope (Other han euanna susan = Form W-2) 5 * ‘oO "No & or .0ss) trom line 3 & rm il2 — 5 corporation for the tania pues satin with or withit!® ~ — > cor —— ~_ a > office tfitter your toxable year. incipal business activity OFLA ce outiitt 27ers. Did you have any centracts or subcontracts subject to t ° yrncent sient sagathave Soeabenu Ce Ey — . Were you a memrer of a controlled grounm subject to the pro- ee Wee tee oe, .....YesQ No visions of section 1S61? Yes &. or section i362? “Yes,” see inst.K. Enter amour! here _.......... Re es io ss neat hee a If so. check tyre of relationship: 1. parent-subs:t:ary “4 i Did you ct er | time during the year own directly o- irsirectl tt 2. brother sister (: combination ef (1) and (2) 5 (ae any siock cl a fcreign corporation?........¥ es CO No section 1563). if “Yes,” attach statement as required by instructicn N. P. renee in 1S€3 a a cf a controlied group Arsutt of ificome (or iccs) for: 1961... 427,727.91: he It a ces vx “ae wed aa mod. Pat | eto? 1962... 374,224.60. 1953. 437.962, 770! Yes ()_No 76 Forva_ 1129 (1964) ‘4 ee Schedule L.—BALANCE SHFETS (See Instructions) mice Beg:rn.nz cf taxatie year End of taxable year ASSETS (A) Amount Pele eee (C) Amount (0) Total ARG TARR eS a es RE RT from toa CAE . kOL, 11b 209 -. 342,72 » 5 2. Notes and accounts receivable.............:eeeeeeeeeees 674, 774.7 776,084.23 (c) Less: Reserve for bod debts. ............2.0ee0005- 674,774.73 776,084.23 es I 6 i550 ae KGS i sad es UR bean cccekebaeesad 5465 537.8) 509, 21.4..25 ic Sn Rk De I iuinesccseucentel. oo ae ee ee re ae ae A I I ss a cccuaniccn 6. Loans to stockholders..............0+5 eéOiaen coucuacces RETA tear NEE 7. Other investments (attach schedule). .............2ss000. Scum ad 479,.954.1 om 505,363.62 8. Buildings and other fixed depreciable assets............. 1 , 4609, 593.16 1,430,305.9 Ge) Rem Dactniduted auudtuaten ond deguectal W2h, 751. 320,035,831. 78 485,614.89 944,691.09 ©, Daphetabln angie .ns > vencssqreecssssecssapescecasestne (a) Less: Accumulated depletion. ...................- : 10. Land (net of any amortization)............cssesseeeeeeee 301,250.00 3712250. 11. Intangible assets (amortizable only)........-....s0.00005 eisai EES TEE SACRE MRT IME nr i. 12, Other ossets (atfach schedule)............0sccesceseeeee 225,437.00 225,505.33 13. pn Ry IIR eat mee geet ges cone peepee 3. 717,835.18 LIABILITIES AND CAPITAL 14. Accounts payable............. Mpths cscbcec she boxupasey 560,636.95 60,409.29 25. Mesiguges, sales, and hands pagable tn less thon 1 your. 14,125.39 2 dh 922.11 16. Other current liabilities (attach schedule)................ 326,753.71 316.099. 17. Loans from stockholders........-...-.-scesecesececeeees Weis FR 18. Mortgages,-notes, and bends payable in | year or more.... 305,787.59 290 , 865.18 12. Other liabilities (attach schedule)................eeeeees Sree ee 20. Capital stock: (a) Preferred stock. «........ 5. oo sn ccc s fonseccenpeonpeqzeccenss OU i ie: 376,860.00! 376,860.00 376.860.00 376,860.00 21. Pcid-in or capital surplus (attach reconciliation) ......... . UN | yepeeecamaas as 56,493.64 22. Surplus Tesrerve (attach schedule) ee AC SEU ea Cage Fee Roe eS eee 22. Earned suxplus end undivided protits...............00008 2297,242, 28 2.200, 151.7) 24. Total liabilities and copital....................... B 637,899.52 3,717, 035-1 ITEMIZED ENTRIES MADE BELOW MUST BE IDENTIFI=D BY ACCOUNT Schedule M-1.—RECONCILIATION OF INCOME PER BOOKS WITH INCOME PER RETURN 1. Net income per books..........sc.seeeeeeres 2325584 28] 7. Income recorded on books this year not in- ee Ce oer ne te L.-LOAaAALaOG! chudled in Gils cotern (emis) ...................4 3. Excess of capital losses over capital gains. ... ancfease in C.S.V..life J 4. Taxable income not recorded on books this -lnusurance..in excess.of....... year (itemize) ' cast ] 7223 25 8. Deductions in this tax return not charged against book income this year (itemize)_......] S. Expenses recorded on books this year not de- -Prior..years state. income ......| ducted in this return (itemize)... eEXCeSs......] taxes contributions. 2,676.50 1,659.10] 9, Total of lines 7 and 8.............-.| 3,599.75 6. Total of lines 1 through 5............- 395,345.16] 10. Income (line 28, page 1)—line 6 less 9..... 391,445.41 Schedule M-2.—ANALYSIS OF EARNED SURPLUS AND UNDIVIDED PROFITS PER BOOKS (line 23, page 4) 1. Balance at beginning of year.............. S. Distributions: (a) Cash SAE oh eC 2. Net income per books. ...........2...eeeeees Bore EE TOT nena ee Me eae a 3. Other increases (itemize) ........---..-.ce--0----- (c) Property ...........005| Ree oe taiedioerine 6. Other decreases (itemize)..........-.-..-----.--- | A Tote! 4 tins S end ©. o.oo ck ss -_———-- 4. Total of liner 1 2. 0nd 3.............. | @. Ealsacos 73 cf ycar Mine 4 less 7).........1 Schedule 2 US COvOR MENT Prot VAG her 8 ed PLS -R gd 77 rom ZO5O0 STATEMENT I SUPPORT — DEDUCTIO:! Rev. July 1962) For Payments to an Employees’ Pension, Profit-Sharing, Stock Bonus Seventinenasibucens Trust or Annuity Plan and Compensation Under a Deferred-Payment Plan Name and address Employer taxable yecr ended June 30, 1965 IVAN ALLEN COMPANY - ATLANTA, GEORGIA Employer identification No. : 580136820 PART I.—DEDUCTION CLAIMED UNDER SECTION 404(a)(1), (2), (3), or (7) 1. Name of plan: Profit sharing pension plan of Ivan Allen Company and subsidiaries 2. Type of plan: 3. If a favorable determination letter has been received indicating —- qualifies under section 401 of the Code, give date of DO Pension or annuity Gd Profit-sharing [) Stock bonus recent determination letter muy. 17,..1956 4. Medium of funding: (Check each applicable box) Gi Meitiadinh oon Group contract: ta) Trusteed plan: _ LD Deposit administration C1 Individual annuity contracts 0 Deferred annuity & Individual contracts containing life insurance © Group permanent DD Self-administered (0 Individual annuity contract 1 Other (Specify) C) Other (Specify) 5. Total number of employees as of the close of the year for each of the following groups based on reasonable estimates: (a) Employees ineligible b of requi ts as to: (iv) Minimum age and not included in (i) through (i) Temporary, seasonal, part-time..... -.....-..--...-.7------- (iii). . Skee eeuetnan (ii) Job classification and not inch ode 4 (v) iene 5 poy y (Solely) .. FETE e Reet enemnnmerenaneennenennee in (i) (e.g., hourly paid, elc.) 20.55) _..2s719.94.__..790.61.. a4 IF PENSION OR ANNUITY FLAN CONTRIBUTIONS | Retirement | Expected Date of Form of Retirement or of oe Benefit ~ -| Under the Plan re) es os eS @) @) © A B c D : E Fr o H I I K L M = R ° P Ne eee eee eee eee eee ee ccmeaciRERRGA® GERMS REIS R B , sep TER u v w x OR BEBE Serene Caneee a8 sence SRE 557 PW NNO eid [EY | SE te he . 10. Have you attached copies of the following which you are required to submit for the first taxable year for which a deduction is claimed or for subsequent years if there is any change in the plan, instruments, methods, factors or assumptions? ITEM YES NO ITEM Tes | NO a. Verified copies of all instruments constituting the plan. in- © A pemmery of Bo prowtstins ond rie a fy = Fy oe (1) Employee eligi ts for in the a brest f ond a re dwtclied de — x cuaneunete, ti x (2) Employee contributions. x b. A stotecent which sets forth: © Saaployer conietbations. Xx (1) Name or names of employers. x (4) The bosis or formula for determining the amount of each (2) Effective date of the plan and any omondments thereto. mY of benefit and the for ob such benefits and the vesting conditions. @) Method of distribution or of disb benefits (whether p.4 by trustee, insurance company, or otherwise). X (¢) The dif: of the plan ond dis- (4) Dotes when the ents dr were executed. X iributions or benefit p. upon d () Dote of forma! announcement. x site: OY eb pm nn é. 8 pension or annutty pion. © detailed description, of of Se employees generally. X So ant bn pees Oe oust bs anneal copes wate’ when iny loot. connngency reserves, ™ Dot plan was put tate olfect. ». 200 204 . 05 34. if tax “line 31, is less thon credits Gine 32).......0.2...... Enter the OVERPAYMENT here conaamnmaty 3S. Enter amount of line 24 vou want: Cred’*ed on 1966 estimcted tax... . Refunded . i Under perwities of perjury | declare ti.ct I heve examined this return, nctading cccomeanving schedules ‘ard statements. an3 * @ ’ the best of my kno ledge and belie! it ta true. correct and complete. If prepared by a person other than taxpayer, his isbesed on all isiormation cf which he has cny knowles 72 -) B 4 —_--—— PS “ Ps ‘ [sae Yk et Tee Li y. CER is Pee’ eam —— Dote ee nt Sigr ature ct cihcer GODFREY, LAWRENCE r noRih BUS tng el gC, ART OR, ON HN , ss A SGM CERTEO PUBLIC anectistA:86.. Sree Sim i me Se 8 1 T609-6 . Al ; ‘ 4 ' ‘ r 1120 0965) Pare? . eS la 4 Si Schedula A—COST “GF “OODS SOLD Him weer a6 ite 4 9 Set rats See instruction 2) = i. Sonie's at bezinnirg of year 498 ,560. 19 S. Total of lines 1 th.. ich 4............ .6,0° i 10° 0e7 4 2. Merchandise boug':t tor manufacture oracle. 4,227, 733.91 6. Less: Inventory at end of year £RS 910.462 q 4. Salaries and wages.....: = : | 7. Cost.ot qods ont (enter here and on line 2, 5 4. Other costs per Dock: (az ch sched!) 1, 32!: ste 1.10! 33 5,145, 22". 4 y Schedule C—INCOME FROM DIVIDENDS . 13 Cortare ' \2 Domestic corpustons |” 15 4., 1. Mame of Geciaring corpo: stion tasarie under chap’er 1, uteltees trea te wrser chapter |, intersst reterred stack | 4. Forergs corprratnns $ Other corporations | Internal Revenue Cote Revenue Code . 2,000.00 j RN ies ous Ke cckenscuree¥ ens te oe I Furniture and fixtures ices onion / , ESR ESEES Heat AMES" SOL" Slee ey E SERRE PES: ¢ Transportation equip:nen : / L i. : Machinery ond cther equipment . r : ; de Other (specify) .. ; ; am oe EEE SE ae eee | . gee Seta ' ! / 4 ) | | Ec at or it : : , 4 Ae iliclna tier :n | swladininieomae hires aelbinn ' | ! ‘ere . | Schedule ' Lg 33,100.03 ; | 86,640.02 7 2 Totals ales 700,03) 2 - -op S40.6 2 ~ Be Less: Shanna ed densoitstenn siniced a Babel be A end eee whare OW TOUGTE: ov isc ok kick 6 Sevcewaveainns ; 38,58) .3: i 4. Balance--Enter here and on lire ~ st J : 69,958 .€ ia aR ” Schedule H—-SUMMARY OF DEPRECIATION tae afer res at ost 9a ser’ “i 2,000. v ver *» Otrer see" “5d co 86 COST _OF GOODS MANUFACTURED IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1966 Other TOTAL MANUFACTURING EXPENSE TOTAL COST OF GOODS MANUFACTURED 4 429.71 a 34,529.93 217,046. Quick- copy Printing Inventory - materials, June 30, 1965 . $ 5,498.10 $ 65,155.96 Purchase#g- materials 94 237.23 594,159.68 Freight 12. 2,605.70 »T40.12 1,921.3 Less inventory - materials, June 30, 1966 6. JO-.194 06 MATERIALS USED ool. $ fa Direct labor © ,566.89 $ 334,288. ™ Manufacturing expenses: Labor - indirect - 69,809.53 Payroll taxes 1,800.00 9,600.00 Rent - building . - 19,800.00 - equipment 1,790.42 797 «25 Heat, power and water - 13,075.18 Depreciation, equipment 1,253.42 17,327.91 Insurance - 5,933.68 Taxes, general - 2,512.Ce Maintenance, equipment 3,675 43 16,365.99 Supplies - departmental 5,371.58 3,259.94 - litho - 3,757.05 - letcerpress - 3,419.26 *- composition 2,782 .82' 5,169.51 - cutting machine . 5. 860.72 - bindery "B" - 1,517.84 - plate making 9,237.25 7,336.26 - collator ° 3,070.04 - rotary press - 1,486.66 - camera - 5,182.57 Outside services 4,183.62 25,650.58 $180 898.59 $1,143, 862.60 In DA HO ODOR INA & a DEO FRE O An Ml FON N) co or oo On S VY Sw Ww Io STATEMENT TF Pc oti.T. PLANT AND QUT fanaa’ TVAN ALLEN COMPANY - ATLAIITA, GEROGIA Year ended June 30, 1966 Allowance for depreciation Cost less _ Balance Jun. 30,1965 Provision Disposals Ju Balance depreciation n. 30,1966 Jun. 30, 1966 Assets 2 ; Balance Balance Jun. 30, 1965 Additions Disposals Jun. 30, 1966 Rental property: Land: 972 Marietta St. $ 35,250.00 $ - $ - $ 35,250.00 1740 Peachtree st. 120,000.00 ° - 120,000.00 221 Ivy st. 150,000.00 - - 150,000.00 660 Forrest Road 72,000.00 - - 72,000.00 Parking lot ~ 56,375.00 . 56,375.00 Buildings: 972 Marietta St.: \ 1948..- 34 81,997.69 - - 81,997.69 Improvements: . . Sprinkler - 1948 - 5¢ past. - - 9,937.00 Roof - 1955 097.84 © - 4,097.84 1740 Peachtree st.: 1959 - 54 - (A) 183,078.48 - - 183,078.48 Improvements - 1959 - (A): . Elevator 10% 15,500.00 ° - 15,500.00 Blacktop - 13.34 6,900.00 - _ 6,900.00 Electrical - 13.34% 31,000.00 - - 31,000.00 Plumbing, heating and air-conditioning - 13.3% 63,000.00 - - 63,000.00 Carpets, etc. - 20% 9,000.00 - - 9,000.00 aed ry 101,012.25 101 - ,012. - . 012.25 1963 addition - 4¢ bby, 765.14 - ° 44 , 765.14 1963 roof - 54 8,156.00 - - 8,156.00 1963 waterproofing and sign - 20% 9,190.54 ~2 - 9,190.54 660 Forrest Road: ; , 1964 = 54 - (A) 124 94 - - 124,558.94 2 L : 23 : heed . ae 196 yet $ 49.2h $ $ 8.76 268 te = 1961-2 25% (A 249.2 - 18.76)(c .00 Plant - 1958 - 20% (a 3,562.7 - - 3,562. 74 Office » 1956 - 204 (A RS - - at bad 1957 bad 204% A . e = .88 = 1959 ~ 204 (A 2,790.79 - 30.90(C) 2,759.89 = 1961 = 20% (A 3,675.00 - - 3,675.00 e 1962 e 25% A 1,673. bad e 1,673.01 = 1964 = 254 (A 3,960.00 - . 3,960.00 = 1965 ~ 25% (A 7,439.50 - - 7,439.50 = 1966 ~ 254 (B - - 29,107.80 29,107.80 4, 3 d 29, 7. 5 Pui 249 42,228.76 2,459.93 - 7,933-01 496.85 - 4,097.8h ao 51,863.46 6,560.75 - 7,674.52 782.55 . 4,166.71 363.53 - 18,715.82 1,633.80 - 20,319.62 37,948.67 3,331.83 . 6,876.63 424.67 Z | $ 35,250.00 120,000.00 150,000.C0 72,000.00 56,375.00 37,308.98 8,429.86 1,507.14 4,097.84 . 58,424.21 124,654.27 10,650.38 41,280.50 21,719.50 T, 301.30 1,698. 70 74,450.39 $ 155.40 $ 28.15 $ - $ 81.97 22. - 2,890.29 134.49 - 4,164.01 114.42 - 329.63 11.85 - 2,264.49 99.08 - 2,320.25 270.95 - 1,043.10 157.48 - 1,362.25 649.69 - 2,083.06 ape - - 47 88.47 23,719. $16,693.05 §$ sores $.0.COCSCOS at 80-0 $ sO ast ts jo ‘ 183.55 $ 84.45 104.87 68.68 3,024.78 537.96. 4,278.43 457.69 341.48 47.40 2,363.57 396.32 2,591.20 1,083.80 1,200.58 472.43 2,010.94 1,949.06 3,422.17 ‘4,017.33 LAN Ee Oat a STATEMENT CF PROPEETY f= % AND EQ Excel - COoNTINVE: : Year ended June 30, 1966 Assets Allowance for depreciation Cost less Balance Balance Balance Balence depreciation Jun. 30, 1°65 Additions Disposals Jun. 30, 1966 Jun.30,1965 Provision Disposals Jun.30,1966 Jun. 30, 1966 $ 1,606.78 $ - $1,606.78 $ - $ 1,562.13 $ - $1,562.13 $ - $ - 3,471.22 ; - 3,471.22 - 3,214.34 - 3,214. 34 - - 1964 Oldsmobile 3,114.68 - 3,114.68 - 2,076.44 - 2,076.44 ° - 1964 Chevrolet - 33 1/3% 2,999.11 - - 2,999.11 1,497.88 999.70 - 2,497.58 501.53 1965 Cadillac 6,581.09 - 6,581.09 - 2,193.70 - 2,193.70 - - 1965 Falcon - 33 1/3% - 2,087.53 - 2,087.53 - 695.84 - 695.84 1,391.69 1966 Cnevrolet - 33 1/3% - 3,303.65 - 3,303.65 - 550.61 - 550.61 2,753.04 1966 Mustang - 33 1/3% - 1,516.88 - 1,516.88 - 252.01 - 252.81 1,264.07 1966 Chevrolet - 33 1/3% - 4,387.39 - 4,387.39 - 1,462.46 - 1,462.46 2,924.93 1966 Buick - 33 1/3% - 4,378.70 - 4,378.70 - T29. - 729.80 3,648.90 1966 Cadillac - 33 1/3% - 6,292.39 - 6,292. 39 ° 1,048.73 - 1,048.73 5,243.66 } 1966 Galaxie - 33 1/3% - 3,486.44 - 3,486.44 - 581. - 581.08 2,905.36 Furniture department: ‘ 19€0 G.M.C. truck 3,783.11 - 3,783.11 - 3,694.44 - 3,694.44 - 1963 Chevrolet stake - 66 2/34 (A) 1,917.35 - - 1,917.35 1,633.39 189.30 - 1,822.69 94.66 19€4 G.M.C. truck 5,815.29 - 5,815.29 - 3,876.46 - 3,876.46 - - 1965 Dodge van - 33 1/3% 1,962.10 - - 1,962.10 654.03 654.03 - 1,308.06 654.04 1966 Dodge van - 33 1/3% - 2,295.69 - 2,295.69 - 382. 62 - 382.62 1,913.07 1966 Dodge truck - 33 1/3% - 6,016.70 - 6,016.70 - 1,002.78 - 1,002. 78 5,013.92 Wrens Hyster - 33 1/3% - 5,064.55 - 5,064.55 - 844.10 - 844.10 4,220.45 1966 Dodge van - 33 1/3% - 3,501.70 - 3,501.76 - 583.61 - 583.61 2,918.09 *Printing department: 1962 Chevrolet panel - 66 2/3% (A) 2,230.61 - - 2,230.61 2,065.51 110.07 oe 2,175.58 55.03 196k Chevrolet S. W. - . 33 1/3% 2,457.03 - - 2,457.03 1,258.48 819.01 - 2,077.49 379.54 Store delivery: } 1962 Ford van 1,476.20 - 1,476.20 - 1,435.19 - 1,435.19 - ~ 5 1962 Ford van 66 2/3% (A) 1,433.31 - - 1,433.31 1,393.37 26.63 _ © 1,420.00 13.31 1962 Chevrolet stake 1,772.89 - 1,772.89 - 1,641.55 - 1,641.55 - 4 1962 Chevrolet panel 1,682.13 - 1,682.13 - 1,557.55 - 1,557.55 - * 1963 Ford van - 66 2/3% (A) 2,012. 38 - - 2,012. 38 1,863.63 99.17 - 1,962.80 49.58 4 1964 Chevrclet panel - 33 1/3% 1,868.96 - - 1,868.96 934.55 622.98 - 1,557.53 311.43 + 1964 Ford van +33 1/3% 2,054.75 - - 2,054.75 342.45 684.92 - 1,027.37 1,027.38 1965 Chevrolet panel - 33 1/3% 2,358.31 - - 2,358.31 373.05 786.10 - 1,159.15 1,199.16 ‘1965 Chevrolet panel - 33 1/3% 2,168.93 - - 2,168.93 361.50 722.97 - 1,084.47 1,084.46 1965 Chevrolet panel - 33 1/34. 1,836.34 - - 1,836. 34 306.06 612.12 - 918.18 918.16 | 19€5 Chevrolet panel - 33 1/3 2,028.29 - 2,028.29 - 338.05 - 338.05 1,690.24 + 1965 Chevrolet panel - 33 1/3% 1,889.55 - 1,889.55 - 314.93 . 314.93 1,574.62 | 1966 chevrolet truck - 33 1/3% - 3,481.35 - 3,482.35 580.22 - 580.22 2,901.13 ) Quick-copy department: 1965 Ford - 33 1/3% 232.00 00 - 6.00 696.00 ' : sal 89 b 4 STATEMENT OF FACTEQUY, PL-NT SD VQUIEMGAY ~ CONCLUDED IVAN ALLZi SOMPANI ~ ATLANPA, GEORG Year ended Jane 3C, 196 q Assets Allowance for depreciation Cost less Balance Balance ‘Balance Balance depreciation Jun. 30, 1965 Additions Disposals Jun. 30, 1966 Jun. 30,1965 Additions Disposals Jur,.30,1966 Jun. 30, 1966 a pcency and equipment: Printing plant: 6 1/44: 1947 $ 11,899.60 $ - § $ 11,899.60 $ 11,699.60 $ - $ - $11,699.60 $ 200.00 1947 29,000.00 - - 29 ,CO0 00 28 ,500.00 - - 28 ,500.00 500.00 1950 455.00 - 455.00 - 440.82 14.18 455.00 - - sop ta) 12,875.20 - - 12,875.20 11,668.15 804.70 - 12,472.85 402.35 A): , 1954 42,135.00 - - 42,135.CO 38,696.59 687. 68 - 39, 384.27 750.7 1956 16, 600.CO - - 16,600.00 14,594.70 401.06 - 143995: 76 1608. 2h 1957 , °858. co - - 3,858.00 3,275.46 116.50 - 3,391.96 466.04 1958 26,527.99 - - 26,527.99 21,520.99 1,001.40 - 22,522.39 4,005.60 1961 10,225.00 . ‘ 10,225.00 5,513.32 9h2.3h - 6,455.66 3,769.34 1963 42,388. 65 - - 42, 388.65 17,014.98 5,074.73 - 22,089.71 20,298.94 1964 38,414.50 - - 38,414.50 12,196.06 5,243.69 - 17,439.75 20,974.75 1965 9,012.50 - - 9,012.50 1,362.14 1,530.07 - 2,892.21 6,120.29 1966 - 13,865.55 - 13,865.55 ~ 1,386.56 - 1,386.56 12,478.99 12 1/2% ~ 1966 - 2,000.00 - 2,C00.CO - 125.00 - 125.00 1,875.00 Quick-Copy department: . 20% (A): 1956 2,687.18 - - 2,687.18 2,281.43 1956 3,173.42 - - 3,173.42 - 2,790.07 1957 1,372.00 - - 1,372.00 1,164.83 1958 2 3856. - - - 2,856. 74 ; 1966 4 823.34 ~ 482 34 A:3) 455.00 $ 273,114.07 $1 807,555.92 $155,902.50 $29,758.39 $2,935. 100-03 1) - 12) - Additional first year depreciation taken on first $1C,C0Q0.CC Declining balance ... Total of l.nes 6 through 9. If applicable, enter here and cn line 3, Part I, and write “alt.” in the margia | 238,490. 72 We Be rhcrtal Cl Wu EM aa ii ioe 06 ii ois Sn Sh on hie ok nds has REE e teen ge be ne be ae bese sew at nsion’ 59— 15-—" 853-1 BED OAL AAD GOA, INSTRUCTIONS Taxpayers Required To File Form 3920.—Com- ponent members of a controlled group of corporations (1) filing a consolidated return, (2) apportioning a single $25,000 surtax exemption under section 1561, (3) electing to claim multiple surtax exemptions under section 1562, or (4) otherwise coming within the ' provisions of section 1561 or 1562, must file Form ~ 3920 wi th their Form 3920 income tax return. ; shall be used to compute the tax in lieu of the tax - computation schedule on Form 1120, Form 1120-F, Form 1120-L, and Form 990-T. Surtax Exemption for Component Members of a Controlled Group of Corporations.— Under section 1561, if a corporation is a component member of a controlled group of corporations on December 31 of its taxable year, the surtax exemption shall be— (1) $25,000 divided by the number of component members on such December 31, of (2) If all members consent to an apportionment plan, their portion of $25,000 determined in ac- cordance with the plan. The sum of the amounts so apportioned shall not exceed $25,000. See section 1561 and the regulations thereunder for time and manner of making the consent. The surtax exemption for a component member which has a short taxable yeat which does not include a December 31 shall be $25,000 divided by the number of component membe’s in the group on the last day of such taxable year. If the surtax exemption is deterrined under (1) or (2) above, the additional 6-perceni tax under section 1562 does not apply. Election of Multiple Surtax Exemptions by a Controlled Group of Cerporatioas.—Subject to the provisions of section 1562, a centrolled group of corporations may elect, with respect to a specified December 31, to have each of its component mem- bers claim a separate $25,000 surtax exemption without having to divide equa!!y or apportion one $25,000 surtax exemption amorg all component memkers. Such election is valid only if each com- ponent member of the group on uch December 3] and each other component member of the group on any succeeding December 31 tefore the day on which the election is made, consens to such election. See section 1562 and the regulations thereunder for Provisions relating to such consent. An election, once made, continues in effect unti terminated in the manner provided in section 1562c). If the group elects to claim multip'e surtax exemptions, each component member must pay an ¢dditional tax of 6 percent on its first $25,000 taxable income. If you are the on!y component membrr of the controlled group which has taxable income or if your surtax exemption has been disallow:d, see section 1562(b)(1). U.S. GOVERNMENT PRINTING CFFICE .195S—O-772-168 Controlled Group of Corporations.—In general, the term “controlled group of corporations’’ means any group of— (1) Parent-subsidiary controlled group.—One or more chains of corporations connected through stock ownership with a common parent corporation if at least 80 percent of the voting power or at least 80 percent of the value of all stock of each of the corporations (except the common parent corporation) is owned by one or more of the other corporations; and if the common parent corporation owns at least 80 percent of the voting power or at least 80 percent of the value of all stock of at least one of the other corporations, excluding, in computing such voting power or value, stock owned directly by such other corporations. (2) Brother-sister controlled group.—Two or more corporations if at least 80 percent of the voting power: or at least 80 percent of the value of all stock of each of the corporations is owned by one person who is an individual, estate, or trust. (3) Combined group.—Three or more corporations each of which is a member of a group of corporations described in (1) or (2) above, and one of which is a common parent corporation included in a group of corporations described in (1) above, and also is a in a group of corporations described in (2) above. (4) Certain insurance companies—Two or more insurance companies subject to taxation under section 802 which are members of a controlled group of corporations described in (1), (2), or (3) above. Such insurance companies shal! be treated as a controlled group of corporations separate from any other corporations which are members of the controlled group Cescribed in (1), (2), or (3) above. For the definition of the term “'stock’’ and for rules relating to the determination of stock ownership, see sections 1563(c) and (Q@). Component Members.—In general, a corporation is a component member of a controlled croup of corporations cn a December 21 of any taxable year if the corporaticn is (1) a member of the controlled group on the December 31 included in such year and is not treated as an eyc: 2 member under section 1563(b)(2) and the regulations thereunder, or (2) is not a member of the contro!led greup on the December 31 but is treated as an additional member under section 1563(b)(3) and the regulations there- under. Alternative Tax.--If the net long-term capital gain exceeds the net short-term,capital loss, or if there is only a long-term capital gain, the alternative tax should be computed to determine if it produces a lesser tax. e30—10—-78553-1 FoRM 3468 @rutatio: OF WVESTHENT creD@H1985 TO BE ATTACHED TO YOUR US. Treesury Department Intemal Revenue Service | 01 taxable year beginning ‘July 2 = 1965, ending .JUNE 30. 19 64 TAX RETURN Name (as shown on page 1 of your tax reiurn) IVAN ALLEN COMPANY Address (number and street) BOX 1712 City or town, and State ATLANTA, GEORGIA 30301 1. Qualified investment in new or used property NOTE: Include your share of investment in property by a partnership, estate, trust, small business corporation, or lessor. ; (1) (2) (3) sy ) Type of A H Applicabl. rf Qualifi west ty Line Life years Cost or basis pp Pp 3 = = roy J (e) ‘nae 33% NEW 6 or more but | (b) 66% PROPERTY less than 8 | nad ci |___47, 796.69 = 47,796.69 USED (@) pins s j | 33% PROPERTY : ' — a oe eee | 66% limitation see | . instructions) 10] 8 of more 2,000.00 | an 2,000.00 2. Total quolified investment—add lines 1(c) throuch (f) 52 SOS ss Vi bde Cadowien Se seasohbssiasss shes 49, fee: 69__ 3. Tentative investment credit—7 “> of line 2 (for puviic utility property, enter 3% OF line 2). ois ciness oss se cnex se 3,495.77. 4. Carryback and carryover of unused credit(s) (attach statement) ce eee cee eee eee S. KOTAL Cine 9 plus: lene 4) -... «cc ceciccincee echeeie oid Gas iadeendsied ogee yeseseeedewaeiseseds 3,485.77 COMPUTATION O OF TAX FOR PURPOSES OF ED en Nore 6. (a) Individuals (enter amount from line 12, page 1, Form 1040) 238,490.72 (b) Estates and trusts (enter amount from line 25 or 26, pose 1, Form 1041) Gad: bckcBta Seo ,4. iS wate arate so. (c) Corporations (enter amount from line 5, Tax Computation Schedule, Form 1120) .............2.2..22 005 7. Individuals, estates and trusts: [ — Recm Ca) Focotgn ten Creel. 00 9. (a) Enter amount on line 8 or $25,000, whichever is lesser © eee eee eee ee eens esaeees mo 28 (b) If line 8 is in excess of $25,000, enter 255% of the excess. eee eee cee eee eee eee eee 8 72, Za () Totel (add lines (a) end (b)).. snare Sihlg aera qnca nines 4 ead Sa wee sig ies Staselaraie esses 3 La : = 10. Investment credit (enter amount on line S or Hc), whichever is lesser)... 3,455.7 SCHEDULE A If any part of your investment in 1 above was made by a partnership, estate, trust, small business corporation, or lessor complete the following: _— Property Nome (Portnenhip, estate, trust, ete.) Address New Used Life yeon s ddcosuandusensencdasteceestsaasceectusscseaessasesecesscsaes $.. psseneceesl ® %s 16—788 12-1 4 ores GENERAL INSTRUCTIONS A. Who Must File.—Any individ estate, trust, or corpora- tion cloiming an investment credit agcinst its tax must attcch this form to its ixcome tax return. Partnerships and small business corporations ore not required to file this form because the credit is claimed by the partner or shareholder. However, partnerships and small business corporations must attach a statement to their returns shewing the allocation of investment to the p or sharehol by amount, type and life of property as shown in item 1 of this form. Estates and trusts which apportion the investment between the estate or trust and the beneficicries should in addition to filine this form attach a statement showing the allocation of the i cf emong the beneficiaries. B. When Allowed.—A credit is allowed against your tax for investment in certain depreciable property having on estimated use- ful life of 4 years or more. The credit is allowed for the first year property is placed in service, even though under the depreciation convention used you mey not be able to claim a deduction for depre- ciation on the property until the following year. C. Property Defined.—The investment credit is applicable to (a) tangible personel property, (b) real property (except for build- ings and their structural components) if used as an integral part of monvufccturing, production or extraction, or used as a research or storage facility in connection with these activities, and (c) elevators and escolators, if their construction, reconstruction, or erection is com- pleted by the taxpayer after June 30, 1963, or if they are acquired after june 30, 1963, and their criginal use commences with the tax- poyer and commences after such date. The investment credit is not applicable to (1) certain property which is used predominantly outside the United Stetes (2) property used for lodging or in connection with furnishing lodging, except (a) property used in certain commercial facilities located therein (such as a restau- ront) or (b) property used by o hotel or motel. (3) property used by a tox-exempt organizction (other than in a business to which the unrelated business income tox applies), (4) property used by governmental units; (5) livestock (including racehorses) D. Election for Leased Property.—A lessor moy elect to treat Gn investment in mew progerty os it made by the lessee instead of the lessor. If the lessor makes this election, then the lessee is treated as if he | the property (see section 42(d) for determination of basis). Where a lessor makes gn election with respect to leased property, such election must be made in accordance with ection 48(d) and the regulations thereunder. E. Replacement Property.—Where insured property is lost or destroyed as a result of a casualty or is stolen, reinvestment of the insurance proceeds in replacement property may not be eligible for in- vestment credit. . F. Disposition of Property.—Where property is disposed of prior to the life used in computing the investment credit, the tax for the year in which the property is so disposed of must be increased by the difference between the credit icken on such property and the credit which would have been allowed had the actual life been used. Such increase should he reported on the line specified on returns other than Form 1040. If you are filing Form 1040, add this amount to the tax to be reported on line 14, page 1, and also show the increase as @ sep amount identified as ‘Inv. Cr." to the left of the total tex. G. Limitations With Respect to Certain Persons.—In the case of (1) mutual savings banks, building and loan associations and . Cooperative banks, (2) a requicted investment company or a reol estate investment trust subject to taxction under Subchaoter M, and (3) @ cooperative organization described in section 1381(a), the qualified investment and the $95,000 limitation shall equol such per- son's ratable share of such items in accordance with section 46(dX2). H. Carryback and Carryover of Unused Credits.—If the emount of the investment credit for any taxable yeor exceeds the limitation, the excess shall be on investment credit carryback to each of the 3 preceding taxable years and an investment credit carryover to each of the 5 succeeding toxable years and shall be added to the emount cllowable as a credit for such years. A clam for refund based upon an unused investment credit carryback should be made on Form 843 of by filing an amended return for the year to which the unused credit is carried. I. Besis and Cost.—The credit for new oroperty applies to the basis of the preperty. The credit for used property applies to the cost of the property. The cost (of used property) does not include the basis of any property traded in. No edjustment for edditionel first-year depreciation or salvage value is required. SPECIFIC INSTRUCTIONS Line 1. New Property.—Enter the basis of property as de- scribed in General Instructions C and | placed in service during the taxable year. In the case of property constructed, reconstructed or erected by you, enter only that portion of the basis which is properly attributable to construction, reconstruction or erection after December 31, 1961, Used Property.—Enter the cost (subject to dollar limitation below) of used property placed in service during the taxcble ycar. See General Instruction | above. Dollar Limitation on Used Pronerty.—In general, the amount of used property token into account may not exceed $50,000. In the case of a husLand and wife filing separcte returns, and each has used property token into account on their returns, the amount moy not exceed $25,000. In the case of a partnership, the $50,000 limitation shall apply with respect to the pertrership and with respect to each partner. In the case of cffiliated grougs, the $50,000 limi- tation shall be reduced for each member of the group by aprortion- ing $50,000 among the members of such group in accorddnce with their respective amounts of used property which may be token into eccount. PAW U.S. GOVERNVENT PRINTING OFFICE 1%5-—-O-780-690 Estates and Trusts.—in the case of an estate or trust the amount of the investment is apportioned between the estate or trust ond the beneficiaries on the basis of the income of the estate or trust allcceble to each. Line 6. Individuals and corporations filing forms other than Forms 1040 and 1120, use the tax figure shown on your return which is comparable to the figure to be used by a taxpayer using Form 1040 or 1120. Line 9. Limitation Boscd on Amount of Tax.—in the case of a husbend and wife filing seperate returns end both have qualified investments, the amount specified on lines 9a) and (b) shal! de $12,500 instead of $25,000. In the case of affiliated groups the $25,000 specified on lines 9c) and (t) shall be reduced for each member of the group by agportioning the $25,000 among the mem- bers of such group. In the case of cn estate or trust the $25,000 limitation specified on lines 9c) and (b) shall be reduced to an amount which beers the same ratio to $25,000 os the amount of qualified investment allocated to the estate or trust bears to the entire quolified investment. 16--78S12-1 @e US. Treasury Oepartsent—Inters d Revenue Serwce -@ SCHEDULE D ; (Form 1120) | GAIIS AD LOSSES FROM SALES OR EXCHANGES OF PROPERTY | 1905 Name and address IVAN ALLEN COMPANY - ATLANTA ,~ GHOPGIA PART I.—GAIN FROM DISPOSITION OF DEPRECIABLE PROPERTY UNDER SECTIONS 1245 AND 1250—Assets Held More Than 6 Months—Where double headings appear, use the first heading for section 1245 and the second heading for section 1250. ©@ Cost or other basis, cost of a a eee necessary, aftach statement of bd. Date acquired ¢ Date seid 4 Grass sates subsequent improvements (if Gescripuce detaris aot shows below) (mo. day. yt.) (mo., 6a. yt.) ome ones pee not purchased. atts: expia- Ration) and expense of sale 1. 1904 Oldsmobile a — -6 | 12-17-65); 1,850.00 | 3,114.68 ~ £. Depreciation atlowed .or wlowarie) since acquisition | ( i Ordinary ain | F wt Aémued pes ae h. a gun (lesser Oe Ser hn) i. a gain e m of t- x ose [em — -OR-— — Sool elated paceman “peendquall —_— “ (see natuctors) ee Prios to January 1, 1964 ee 163 - 2,076.44 125038228 fa! 811.790 0). 505 iy (S00 2. Total ordinary gain. Enter here and on line 1] as gain from PartI....... 811.76 a PES | 3. Total other gain. Enter here and on lire 4 end :d-n* fy a3 gan frem Past! ae : PART II.—SALE OR EXCHANGE OF PROPERTY P UNDER SECTION | 1231 i @. Depreciation al ‘owed 1. Cost or other basis, | c te ace 5 a cost of susequent im- gi (lowe } chengreny Gane chor pagel tog) agony (sean + | d. Gross sates price | (OF alowarle) since | | brovements tnt ar | . id . | chased attach expiuna- catiaen schedule) ton) and expense ot sale. . Gain or & plus Identify as atin or less from Part IL)..... 000. 7 / PART III.—CAPITAL ASSETS Short-Term Capital Gains and Losses—Assets Held Not More Than 6 Months 1. Unused capital le:3 ca 8. Total of shert tr. cecita! t3ins cr my Long-' -Term: Capital Goins and i Lovses— Assets held Moré Than 6 Months s let ween chertlerm cartal ciinsard lessees esarile | 255,100, 22 PART IV—PROVERTY OTHER THAN CAPITAL ASSETS 12, Total net gain (or Ieee). Enter bore ord on Ene 15 POOR Copy rl 99 Schedule D Form 1120) 195° — is ee ee 2. Page 2 PAW V.—TOTAL 2CHEDULE D GAINS AND en term capital gain (line 3) over net loagtern. 14, E-+ she ere sucka is Vlerm ecetah ye Foe I cyne nat het ee og 1 —* 255,100.22" 18. Net gsiss (eos) from prs ¢ ts dine 12)... ee cee eee j 811.75 16. Tete) ines 13,14 ard 15 Enter here ar. 3 on Form 1179 page | line 9 ; ae i 255,920.95 Alternative Tax Computation (Component members of contiolled corporate group use Form 3920 to compute your tax) 17. Taxabie income (line 30, page |, Form 1120). eases Gils 2.6424 6o 0G 54 ne bowels soba relg oie gis vesee els Uecewces get deeetiedencseesse 18. Net long-term capital gain reduced by any net short-term capital bas lines 14) 0.560 oe'ess%0% een apiere-eies 19. Line 17 minus line 18....... eevies.4ars dee Dee Serer ew iaaeon ees ee ureatetere'sieg-a.e bea daeees Saisie icra dieses 20. If amount of line 19 is (a) Not over $25,000—Entor 22 percent of line Dc ie pesseeee 7 (b) Over $25,000-—Enter 48 percent of line 19. Subtract $6.509 and enter difference 21. 25 percent of iine 18......... ia bieibase tars ee ceeatae seine 22. Alternative tax (line 20 lus line 21). Ifapnlicable, en the margin to the righ’ cf the entry _ ' INSTRUCTICZUS (References are to the Internal Revenue Code) Gains and losses from sales or ene of copital assets | Gains from section 1245 or 1250 property held more than6 ; and other property. — 2 of car months (Part I).--(Reporr any gain from such propsrty pe aed exch held for 6 manger te or less in Part IV.) Except asp ied nedule D. Ev- 2 Seprecicbis (a) perso: gain or loss may be ind SngIEi fone Lesses from s. only tothe extent cfg. the amount ofa netic curred over to e . tothe extent sucn ate to each of the te : shal! be treat “4 ; short term i / agi: ; betweer, t! he te . tained ard th Definition o Mears propert with its tra of th 195 ero oe 7 ~"As é nm 1250 property means de- i Sce eoction “1245; ) end 125¢ tions invol: ing: 2) c:: 2 Ch G*Orec.ct.on cemcute *” z e . % - - - 7 ud ' te ’ z "2 - ) c eves Joh : : : ~is BGs ci 5 Losses on securiti.s becom z i ‘ : : Armes ab ao me oe te S29 Se ten | a aa eae es : ansutienent sale es.- [f terc eek we tg we cee oe ole 7 oe : Crietic he ccse > “Mal--: seae - a.e : on warty 100 TAX SCHEDULE - 58-0136820 IVAN ALLEN COMPANY - ATLANTA, GEORGIA Year ended June 30, 1966 DIVIDENDS REC [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386414_0446%3A01. Public record. Not legal advice.