STANDARD MANUAL OF THE INCOME TA) 1919 PUBLiSHED BY STA NDARD STAT IS TIGS CO.. In NEW YORK. U.S.A. Standard Manual of the Income Tax 1919 Published by ATisncs 47 West Street, New York STANDARD STATISTICS COMPANY, Inc. Copyright 1919 STAITDARD STATISTICS CO., Inc. New York Table of Contents SECTION I. Page Condensed Digest and Changes of the War Revenue Law of 1918 11 Full Text of the Act with Marginal Notations 51 General Index .— Buff pages Detailed Digest of the Law-_ 177 SECTION II. Page High and Low Prices of Securities as of March 1, 1913— 1003 Treasury Decisions, Court Decisions and Other Income Tax Data 1201 Collection Districts — Complete List 1365 Additional Income Tax Schedules for Previous Years 1371 d 1 i'rOA t The information contained here- in, while not guaranteed, has been carefully compiled, and is believed to be correct. Section I CONTENTS. Condensed Digest of Law. Full Text of Act. General Index. Detailed Digest of Law. [On the following pages will bb foui»d a digest «f'th*«. New Revenue Law. This digest wa's prejpatfed to 'familiar-' ize the user of this book with the general provisions of the Act, particularly the changes therein, and to serve as a groundwork for utilizing the more detailed information which begins on page 177.] DIGEST AND CHANGES OF THE REVENUE ACT OF 1918 INDIVIDUALS. The first taxable year shall be the calendar year 1918 or any fiscal year ending within the taxable year. Individuals, partnerships, and certain personal service corporations are exempt from the Excess Profits Tax. Members of partnerships are liable for Income Tax on the net profits of the partnership whether distributed to them or not. This same provision applies to the stockholders of a personal service cor- poration. Every individual having a net income for the taxable year of $1,000 or over, if single or if married and not living with husband or wife, or the head of a family; or $2,000 or over if married and living with husband or wife, will be required to render a return. Therefore, every single individual with a net income of $19,24 per week or over, or a married individual with a net income of $38.47 per week or over, must make a return. In the year 1917 there were two income tax laws in force. Under the Act of September 8, 1916, as amended, the exemption for a single person was $3,000, and for a married person $4,000. Under the Act of October 3, 1917, the exemption for a single person was $1,000, and for a married person $2,000. Husband and Wife. If the combined net income of husband and wife, living together, and dependent children equaled or exceeded $2,000, all such income must be reported, either on one return or on separate returns. If separate returns are made, the exemption of $2,000 may be divided between them or the husband can take the full exemption and the wife pay the tax on her entire net income, or vice versa. The combined amount of exemption taken must not exceed $2,000. If the individual net income of either the wife or husband exceeds $5,000, separate returns must be filed as the additional tax of each is computed separately. Separate returns must also be filed if the husband and wife are not living together and the net income of either is $1,000 or more. 11 Individual Liability to Make ReturiL WhtDever,i^ the judgment of the Commissioner necessary, he may require any person, by notice served upon him, to make a return or such statements as he deems sufficient to show whether or not such person is liable to tax. Returns may be made to the collector of internal revenue for the district in which the taxpayer has his legal residence or in the district in which is located his principal place of business. (Under the previous Act the taxpayer was requested for administrative purposes to file the leturn in the district in which he resided.) STATUS OF TAXES DUE THE UNITED STATES. The tax due on income has the status of a debt due to the United States, and persons receiving property charged with such indebted- ness must answer for the debt. PAYMENT OF TAX. Payment of Tax in Installments. The tax may be paid in four installments, covering the entire year, up to December 15th, 1919. The first payment is due at the time of filing the return, that is, March 15th, 1919,* if the return is made on the basis of the calendar year 1918. The second payment is to be made on June 15th, the third payment on September 15th and the fourth and final payment on December 15th. ♦Unless this date is automatically extended 13 under the provisions of the Act of October 3, 1913, except that the taxes imposed under the Act of August 5, 1909, and paid by the corporation within the year shall be included, and except that the amounts received by it as dividends upon the stock, or from the net earnings of other corporations sub- ject to the tax imposed by the Act of October 3, 1913, shall be deducted. For the taxable year upon the same basis and in the same manner as provided for income tax purposes under Title IT. of the present Act. Average Net Income for Pre- War Period. The average net income for the pre-war period shall be determined by dividing the number of years within that period during the whole of which the corporation was in existence, into the sum of the net income for such years, even though there may have been no net income for one or more of such years. ADVANTAGE OF ASCERTAINING PRE-WAR INCOME. As the present Act provides that a part of the war profits credit shall be the amount of the average net income of the corporation for the pre-war period, in no case to be less than 10 per cent, of the amount of the invested capital for the taxable year, it naturally follows that if the average earnings of the corporation for the years 39 1911, 1912 and 1913 were substantially larger than an amount equal to 10 per cent of the invested capital for the taxable year, it would be decidedly advantageous to the corporation to determine this pre- war average, thereby increasing the war profits exemption tending to reduce the amount of tax payable under the third bracket. Liberty Bonds. Liberty bonds of all issues shall be included in invested capital if purchased with profits or surplus earned prior to the taxable year. Liberty bonds purchased with earnings of the taxable year cannot be included in invested capital. Inadmissible Assets. Inadmissible assets in addition to those which produce income that is not subject to the tax includes borrowed capital and any assets which represent earnings of the taxable year. There shall be deducted from invested capital that proportion of the total assets which the inadmissible assets is of the admissible and inadmissible assets held during the year. In other words, if the total assets are $100,000, of which $25,000 are inadmissible assets such as mimicipal bonds, etc., the invested capital would be $75,000. Admissible Assets. Admissible assets, that is those which constitute invested capital, includes: (1) Actual cash bona fide paid in for stock or shares; (2) Cash value of tangible property paid in for stock or shares at the time of such payment, but in no case to exceed the par value of the original stock or shares specifically issued therefor, \mless it is shown to the satisfaction of the Commissioner that the actual cash value of such property was really and substantially in excess of the par value of the stock or shares at the time paid in; (3) Paid-in or earned surplus or profits earned prior to the taxable year; (4) Intangible property bona fide paid in for stock or shares prior to March 3, 1917, in an amount not exceeding either the actual cash value of such property at the time paid in on the par value of the stock or shares issued therefor or in the aggregate not exceeding 25 per cent of the par value of the total stock or shares of . the corporation outstanding on March 3, 1917, whichever is lowest. (5) Intangible property bona lid e paid in for stock or shares on or after March 3, 1917, in an amount not exceeding either the actual cash value of the property at the time paid in or the par value of the stock or shares issued therefor or in the aggregate not exceeding 25 per cent of the par value of the total stock or shares of the corporation outstanding at the beginning of the taxable year, which- ever is lowest. In no case shall the value of intnngible property paid in for stock or shares, whether paid in prior to or subsequent to March 1, 1913 40 (the date of inception of the lirst income tax Act), exceed 25 per cent of the par value of the total stock or shares of the corporation outstanding at the beginning of the taxable year. When Inadmissible Assets May Be Included. If a corporation owns inadmissible assets, such as stocks, munici- pal bonds, etc., the dividends or interest upon which are not subject to the tax and the income derived from these assets consists partly of profits realized from their sale or other disposition, which have been included in net income, then a corresponding amount of the capital invested in such assets shall be included as invested capital. If money is borrowed to purchase inadmissible assets. Section 234, Subdivision "A," Paragraph 2, provides that the interest on this indebtedness is not allowable as a deduction from net income. As the interest on this borrowed capital is an actual expense to the corporation, and the interest is not allowable as a deduction from net income, it naturally follows that the corporation is paying a tax upon so much dividends or interest received from the stocks, municipal bonds or other inadmissible assets which were purchased with the borrowed money, as equals the amount of interest paid upon the capital borrowed to purchase them. In this case, if the corporation is actually paying a tax upon the income received from inadmissible assets because of the deduction of interest being lim- ited by Section 234, a corresponding part of the capital invested in such inadmissible assets shall be included in invested capital. Excess of Inadmissible Assets Over Indebtedness. The excess of the average amount of inadmissible assets for the year over the average indebtedness for the year shall be deducted from invested capital. The probable theory of this deduction is to prevent a corporation from borrowing capital to invest in tax-free securities; the income from the tax-free securities being exempt from tax, and the interest on the indebtedness being deductible as an expense. When Invested Capital Cannot be Satisfactorily Determined. In cases where the invested capital cannot satisfactorily be de- termined due to any of the following reasons enumerated below as items (1) to (5), the tax shall be the amount which bears the same ratio to the net income (in excess of the specific exemption of $3,000) as the average tax of representative corporations en- gaged in a like or similar trade or business bears to the average net income if representative corporations Avhose invested capital has been satisfactorily determined by the Commissioner and which are, as nearly as may be, similarly circumstanced with respect to gross income, net income, profits per unit of business transacted and capital employed, the amount and rate of war-profits or excess- profits, and all other relevant facts and circumstances. (1) Where the Commissioner is unable to determine the invested capital as provided in Section 326; 41 (2) In the case of a foreign corporation; (3) Where a mixed aggregate of tangible property and intangible property has been paid in for stock or for stock and bonds and the Commissioner is unable satisfactorily to determine the respective values of the several classes of property at the time of payment, or to distinguish the classes of property paid in for stock and for bonds, respectively; (4) Where upon application by the corporation the Commissioner fineds and so declares of record that the tax if determined without benefit of this section would, owing to abnormal conditions affecting the capital or income of the corporation, work upon the corpora- tion an exceptional hardship evidenced by gross disproportion between the tax computed without benefit of this section and the tax computed by reference to the representative corporations speci- fied in section 328. This subdivision shall not apply to any case (1) in which the tax (computed without benefit of this section) is high merely because the corporation earned within the taxable year a high rate of profits upon a normal invested capital, nor (2) in which 50 per centum or more of the gross income of the corporation for the taxable year (computed under section 233 of Title II) consists of gains, profits, commissions, or other income, derived on a cost- plus basis from a Government contract or contracts made between April 6, 1917, and November 11, 1918, both dates inclusive. CONSOLIDATED RETURNS BY AFFILIATED CORPORATIONS. Corporations shall be deemed to be affiliated and required to make consolidated returns both for the purpose of the war excess-profits and corporation income taxes if one corporation owns directly or controls through closely affiliated interests or by a nominee or nominees substantially all the stock of the other or others; or if substantially all the stock of two or more corporations is owned or controlled by the same interests. That there shall be taken out of such consolidated net income and invested capital, the net income and invested capital of any such affiliated corporation organized after August 1, 1914, and not succes- sor to a then existing business, 50 per centum or more of whose gross income consists of gains, profits, commissions, or other income, derived from a Government contract or contracts made between April 6, 1917, and November 11, 1918, both dates inclusive. In such case the corporation so taken out shall be separately assessed on the basis of its own invested capital and net income and the re- mainder of such affiliated group shall be assessed on the basis of the remaining consolidated invested capital and net income. Wlien the tax is assessed upon the basis of a consolidated return, the tax shall be computed in the first instance as a unit and shall then be assessed upon the respective affiliated corporations in such proportion as may be agreed upon among them; or in the absence of any such agreement, then on the basis of the net income assign- able to each. In computing the tax, there shall only be allowed one ipeciflc credit of $3,000 for the purpose of computing the excess -profits credit and one specific credit of $3,000 for the purpose of the war-profits credit and one specific credit of $2,000 for the purpose of the cor- poration income tax. 42 THE CORPORATION INCOME TAX. In addition to the war-excess profits tax, Section 230 of the Act, levies a corporation income tax of 12% on the net income of corporations. Returns are to be filed at the same time as for the war excess- profits tax and payment is to be made 'in the same manner. Every corporation "subject to taxation under this Title" is re- quired to make a return. As the Corporation Income Tax under Section 230 allows domestic corporations a specific exemption of $2,000, it is assumed in the absence of a ruling, that corporations whose net income is less than $2,000 are not required to file a return. Credits Allowed. In arriving at the amount of net income that is subject to this tax, there must first be deducted as credits the amount of the excess-profits tax paid or payable for the same taxable year, the interest received upon obligations of the United States and bonds of the War Finance Corporation which has been included in gross income and the specific exemption of $2,000 allowed to all domestic corporations. FOREIGN CORPORATIONS. Foreign corporations are taxable only upon income derived from sources within the United States, including the interest on bonds, notes or other interest-bearing obligations of residents, corporate or otherwise, dividends from resident corporations and including all amounts received (although paid under a contract for the sale of goods or otherwise) representing profits on the manufacture and disposition of goods within the United States. Foreign corporation are not allowed the specific exemption of $2,000. WHAT CONSTITUTES GROSS INCOME. The gross income of a corporation has the same meaning as defined in the case of an individual; namely, all gains, profits and income derived from salaries, wages or compensation for personal service of whatever kind and in whatever form paid; or from professions, vocations, trades, businesses, commerce or sales, or dealings in prop- erty, whether real or personal, growing out of the ownership or use of or interest in such property; also, from interest, rent, dividends, securities or the transaction of any business carried on for gain or profit or gains or profits and income derived from any source whatever. INSURANCE ON LIVES OF OFFICERS OR EMPLOYEES. Amounts received as insurance upon the lives of officers or em- ployees, by a corporation, upon the death of the insured constitutes taxable income to the corporation. The amount of premiums paid may be deducted from the total received and the tax paid on the net amount. 43 DEDUCTIONS ALLOWABLE FROM GROSS INCOME. AH the ordinary and necessary expenses paid or accrued during tlie taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other compensation for personal services actually rendered and including rentals or other payments required to be made as a condition to the continued use or possession of property. Payments of Interest by Domestic or Foreign Corporations. All interest paid or accrued within the taxable year on indebted- ness. In the case of a foreign corporation only the proportion of such interest which the amount of its gross income from sources within the United States bears to the amount of its gross income from all sources within and without the United States. All taxes paid or accrued within the taxable year, except Income, War-Profits and Excess -Profits taxes and those assessed against local benefits of a kind tending to increase the value of the property assessed. Foreign Corporation Taxes. In the case of a foreign corporation, all taxes imposed by the authority of any foreign country (except Income, War-Profits and Excess-Profits taxes and taxes assessed against local benefits of t, kind tending to increase the value of the property assessed) upon the property or business. LOSSES AND DIVIDENDS DEDUCTIBLE. All losses sustained during the taxable year and not compensated for by insurance or otherwise; all debts ascertained to be worth- less and charged off within the taxable year and all dividends re- ceived from corporations which are taxable upon their net incomes. Obsolescence, and Amortization of War Material. A reasonable allowance for the exhaustion, wear and tear of prop- erty used in trade or business, including a reasonable allowance for obsolescence. In the case of buildings, machinery, equipment ac- quired or vessels constructed or acquired on or after April 6th, 1917, contributing to the prosecution of the present war, there shall be allowed a reasonable deduction for the amortization of such part of the cost of such facilities or vessels as has been borne by the tax- payer. Re-examination Within Three Years. At any time within three years after the termination of the pres- ent war, the Commissioner of Internal Revenue may, at the request of the taxpayer, make a re-examination of the returns in order to determine if proper allowance has been made for this item of amor- 44 tization, and if upon re- examination it is found that the original deduction allowed was incorrect, the amount of taxes for the years affected will be redetermined and any tax which may be found to have been overpaid, will be refunded or credited to the taxpayer. Depletion of Oil and-Gas Wells. In the case of mines, oil and gas wells, other natural deposits or timber, the reasonable allowance for depletion and depreciation of improvements will be allowed according to the peculiar conditions in each case, based upon cost, including cost of development not otherwise 'deducted. Market Value of Mines, Oil and Gas Wells. In tlie case of the above properties discovered by the taxpayer on or after March 1st, 1913, where the fair market value of the property is materially disproportionate to the cost of depletion, allowance shall be based upon the fair market value of the property at the time of discovery or within 30 days thereafter. These allowances are to be made in accordance with rules and regulations to be prescribed by the Commissioner with the approval of the Secretary. Lessor and Lessee Apportionment. In the case of leases, the deductions allowed by this Section shall be equitably apportioned by the lessor and lessee. Net Losses Applicable to Other Years. In the case of net losses discovered for the first time during the period between November 1st, 1918, and January 1st, 1930, if the facts are sustained by evidence which is satisfactory to the Commissioner, such losses may be credited against the net income of the preceding year and the taxes redetermined accordingly, as outlined in a fore- going paragraph entitled "War Losses Deductible Against Prior Year's Income." Indebtedness Incurred to Purchase Liberty Bonds. Interest paid or accrued on indebtedness incurred or continued to purchase or carry obligations of the United States issued after Sep- tember 24th, 1917, is an allowable deduction. DEDUCTIONS NOT ALLOWABLE, Premiums paid on any life insurance policy covering the life of any official or employe of or any person financially interested in any trade or business carried on by the taxpayer, when the tax- 45 payer is directly or indirectly a beneficiary under such policy. Any amount expended in restoring property or in making good the ex- istence thereof, for which an allowance is or has been made. Improvements and Betterments. Any amount paid out for new buildings or for permanent improve- ments where betterments are made to increase the value of any property or estate. Taxes Paid on Bond Interest Not Deductible. In the case of corporations issuing bonds or other obligations which contain a tax-free covenant, that is, a contract or provision by which the corporation agrees to pay any portion of the tax imposed upon the bondholder or to reimburse the bondholder for any tax which he may be required to pay, the amount of tax withheld and paid pursuant to this contract or provision shall not be allowed as a deduction from net income by the corporation. Interest on Indebtedness Incurred to Purchase Tax Exempt Securities Any amount of interest paid or accrued within the taxable year to purchase or carry obligations or securities, the income from which is wholly exempt from taxation, shall not be allowed as a de- duction. Interest paid or accrued on indebtedness incurred or continued to purchase or carry obligations of the United States issued prior to September 24th, 1917, shall not be an allowable deduction. WITHHOLDING TAX ON BOND INTEREST AT THE SOURCE WHERE BONDS CONTAIN A TAX-FREE CLAUSE. In any case where bonds, mortgages, or deeds of trust, or other similar obligations of a corporation, contain a contract or provision by which the obligor agrees to pay any portion of the tax imposed by this title upon the obligee, or to reimburse the obligee for any portion of the tax, or to pay the interest without deduction for any tax which the obligor may be required or permitted to pay thereon, or to retain therefrom under any law of the United States, the obligor shall deduct and withhold a tax equal to 2 per cent of the interest upon such bonds, mortgages, deeds of trust or other obliga- tions, whether such interest is payable annually or at short or longer periods, and whether payable to a non-resident alien individual or to an individual citizen or resident of the United States, or to a partnership: Provided, That the Commissioner may authorize such tax to be deducted and withheld in the case of interest upon any such bonds, mortgages, deeds of trust or other obligations, the owners of which are not known to the withholding agent. In the case of a citizen or resident entitled to receive such interest, the withholding shall not be required if he files with the withholding 46 agent on or before February 1st a signed notice in writing claiming the benefits of the exemption of either $1,000 or $2,000, according to his marital status. Filing of Withholding Returns. The returns by corporations of any- -tax so withheld upon bonds containing a tax-free clause, shall be made with the Collector of In- ternal Revenue on or before March 1st of each year and payment must be made on or before June 15th. Owing to the fact that the present Act was not passed until the latter part of February the filing date of the withholding returns above mentioned will probably be extended. Contract Between Issuing Corporation and Bondholder. The Government has consistently held that the so-called tax-free covenant in bonds is a contract between the issuing corporation and its bondholders with which the Government has no concern. Inas- much, however, as the great majority of the tax-free covenants in bonds are to the effect that the issuing corporation "will pay coupons, etc., without deduction for any Federal income taxes which the cor- poration is obliged by law to retain and pay" the provision limiting the amount to be retained and paid at the source to 2% was prob- ably designed as a measure of relief to minimize the obligation of the issuing corporation to its bondholders. The 2% tax on bond interest to be withheld and paid at the source in the case of bonds containing a tax-free covenant is only a part of the tax assessed on interest from bonds, the bondholder being liable for tax on such interest at the full normal and super- tax rates prescribed by law. PAYMENTS TO NON-RESIDENT ALIEN INDIVIDUALS. All individuals, corporations and partnerships making payments of interest, rent, salaries, wages, premiums, annuities, compensations, remunerations, emoluments or other fixed or determinable annual or periodical gains, profits, or income to any non-resident alien individ- ual, shall deduct and withhold from such payments a tax equal to 8% thereof. Withholding of 8 Per Cent Tax on Payments to Non-Resident Aliens. The foregoing docs not apply to payments of dividends by cor- porations taxable upon their net income, or payments of interest upon bonds or other corporate obligations containing a tax-free clause. BONDS NOT CONTAINING A TAX-FREE CLAUSE. If the bonds do not contain a tax-free clause, the Government imposes no obligation upon the corporation for payment of the tax at the source, when paid to citizens or residents, the tax in this case being paid by the bondholder. 47 BOND INTEREST PAID TO NON-RESIDENT ALIENS. In the case of bond interest paid to non -resident alien individuals or non-resident alien corporations, the tax is to be withheld by the issuing corporation in every case whether or not the bonds contain a tax-free clause. When the bonds contain a tax-free clause the amount to be with-, held from non-resident aliens is 2 per cent. When the bonds do not contain the tax-free clause the amount to be withheld is 8 per cent. BOND INTEREST PAID TO NON-RESIDENT ALIEN CORPORATIONS. When the bonds do not contain a tax-free clause the amount to be withheld from non-resident alien corporations is 10%. License For Collection of Foreign Items. That all individuals, corporations, or partnerships undertaking as a matter of business or for profit the collection of foreign pay- ments of interest or dividends by means of coupons, checks, or bills of exchange shall obtain a license from the Commissioner and shall be subject to such regulations enabling the Government to obtain the information required under this title as the Commissioner, with the approval of the Secretary, shall prescribe; and who- ever knowingly undertakes to collect such payments without having obtained a license therefor, or without complying with such reg- ulations, shall be guilty of a misdemeanor and shall be fined not more than $5,000, or imprisoned for not more than one year, or both. Licenses Under Previous Acts. Any person, corporation, individual, or partnership holding a license secured under previous Acts will not be required to take out a license under the present Act. Licenses For Branch Offices. If licenses are required for branch offices the collector for the district in which the home office is located, if so notified, will issue the necessary authority to the collectors of the districts in which are located any branch offices for which any additional licenses are required. The Special Excise Tax On Corporations. Every corporation shall pay annually a special excise tax with respect to carrying on or doing business equivalent to $1.00 for each $1,000 of so much of the fair average value of its capital stock for the preceding year ending June 30th as is in excess of $5,000. 48 In estimating the value of capital stock the surplus and undi- vided profits shall be included. This tax shall not apply to any corporation which was not engaged in business during the pre- ceding year ending June 30th nor to any corporation which is exempt from the corporation income tax or the war excess -profits tax, nor to any foreign corporation not engaged in business in the United States during the preceding year ending June 30th. Special Excise Tax On Foreign Corporation. Every foreign corporation shall pay annually a special excise tax with respect to carrying on or doing business in the United States equivalent to $1.00 for each $1,000 of the average amount of capital employed in the transaction of its business in the United States during the preceding year ending June 30th (without the specific exemption of $5,000 accorded to domestic corporations). ADDENDA Bonds That Do Not Contain a Tax-Free Covenant. The Commissioner has ruled that under the law, a corporation issuing bonds without a tax-free covenant is not permitted to de- duct or pay tax at the source with respect to the interest thereon; except in cases where bonds are owned by a non-resident individual or corporation not having an office or place of business in the United States. The withholding provisions of the law apply to the normal income tax derived from interest payments upon bonds which do not con- tain a tax-fi'ee covenant clause only in cases where the bondholders are non-resident alien corporations or individuals. If interest payments are made to citizens or residents of the United States from bonds which are not tax-free, such income must be reported on Form 1001,* Revised, as there is no provision for reporting this income as subject to withholding. Should a corporation desire to reimburse its bondholders in such cases, it may do so, as this is a matter wholly between the parties concerned and one in which the Government is not interested. How- ever, such income should not be reported as subject to withholding and this office will not accept tax deducted in such cases by the withholding agent. *0r its equivalent under any new regulations. 49 The Revenue Act of 1918 AN ACT To provide revenue, and for other purposes. 1 Be It enacted by the Senate and House of Representa- 2 tlves of the United States of America in Congress 3 assembled, 4 '^ B 6 TITLE I.— GENERAL DEFINITIONS. 7 8 SECTION 1. That when used in this Act — 9 The term "person" Includes partnerships and cor- lo "Person" porations as well as Individuals; 11 The term "corporation", includes associations, joint- 12 "Corporation" stock companies, and Insurance companies; 13 The term "domestic" when applied to a corporation or 14 "Domestic" partnership means created or organized in the United 15 States; 16 The term "foreign" when applied to a corporation 17 "Foreign" or partnership means created or organized outside the 18 United States; 19 The term "United States" when used in a geographl- 20 "United States" cal sense includes only the States, the Territories of 21 Alaska and Hawaii, and the District of Columbia; 22 The term "Secretary" means the Secretary of the 23 "Secretary" Treasury; 24 The term "Commissioner" means the Commissioner 25 "Commissioner' of Internal Revenue; 26 The term "collector" means collector of Internal 27 "Collector" revenue; 28 The term "Revenue Act of 1916" means the Act en- 29 "Revenue Act titled "An Act to increase the revenue, and for other 30 of 1916" purposes," approved September 8, 1916; 3a The term "Revenue Act of 1917" means the Act en- 32 "Revenue Act titled "An Act to provide revenue to defray war ex- 33 of 1917" penses, and for other purposes," approved October 3,34 1917; 35 The term "taxpayer" Includes any person, trust or 36 "Taxpayer" estate subject to a tax imposed by this Act; 37 The term "Government contract" means (a) a con- 38 "Government tract made with the United States, or with any depart- 39 Contract" ment, bureau, officer, commission, board, or agency, un- 40 der the United States and acting in its behalf, or with 41 any agency controlled by any of the above If the con- 42 tract is for the benefit of the United States, or (b) a sub- 43 contract made with a contractor performing such a con- 44 tract if the products or services to be furnished under 45 the subcontract are for the benefit of the United States. 46 The term "Government contract or contracts made 47 51 'Military or Naval Forces 1 between April 6, 1917, and November 11, 1918, both 2 dates inclusive" when applied to a contract of the 3 kind referred to in clause (a) of this paragraph, in- 4 eludes all such contracts which, although entered into 6 during such period, were originally not enforceable, 6 but which have been or may become enforceable by 7 reason of subsequent validation in pursuance of law; 8 The term "taxable year" mens the calendar year, 9 States" includes the Marine Corps, the Coast Guard, of the United 10 the Army Nurse Corps, Female, and the Navy Nurse States" 11 Corps, Female, but this shall not be deemed to exclude 12 other units otherwise included within such term; 'Present War" 13 The term "present war" means the war in which the 14 United States is now engaged against the German Gov- 15 ernment. 16 P'or the purposes of this Act the date of the termina- 17 tion of the present war shall be fixed by proclama- 18 tion of the President. 19 21 22 TITLE II.— INCOME TAX. PART Z.-~ GENEBAI^ PROVISIONS. 'Taxable Year' Federal Year' Fiduciary" 'Withholding Agent" 'Personal Service Corporation' 26 Definitions. 26 27 SECTION 200. That when used in this title— 28 The term "taxable year" means the calendar year, 29 or the fiscal year ending during such calendar year, 30 upon the basis of which the net income is computed 31 under section 212 or section 232. 32 The term "fiscal year" means an accounting period 33 of twelve months ending on the last day of any month 34 other than December. The first taxable year, to be 35 called the taxable year 1918, shall be the calendar year 36 1918 or any fiscal year ending during the calendar year 871918; 38 The term "fiduciary" means a guardian, trustee, ex- 39 ecutor, administrator, receiver, conservator, or any 40 person acting in any fiduciary capacity for any per- 41 son, trust or estate; 42 The term "withholding agent" means any person re- 43 quired to deduct and withhold any tax under the pro- 44 visions of section 221 or section 237; 46 The term "personal service corporation"' means a 46 corporation whose Income is to be ascribed primarily 47 to the activities of the principal owners or stockhold- 48 ers who are themselves regularly engaged in the active 49 conduct of the affairs of the corporation and in which 60 capital (whether invested or borrowed) is not a mate- 61 rial income-producing factor; but does not include any 62 foreign corporation, nor any corporation 50 per centum 63 or more of whose gross income consists either (1) of 64 gains, profits, or income derived from trading as a 65 principal, or (2) of gains, profits, commissions, or 66 other income, derived from a Government contract or 57 contracts made between April 6, 1917, and November 11, 68 1918, both dates inclusive; 52. The term "paid," for the purposes of the deductions 1 "Paid," and credits under this title, means "paid or accrued" 2 "Paid or or "paid or incurred," and the terms "paid or incurred" 3 Accrued," and "paid or accrued" shall be construed according to 4 "Paid or the method of accounting upon the basis of which the S Incurred" net Income is computed under Section 212. 6 7 8 Dividends. 9 10 SECTION 201. (a) Tliat the term "dividend" when 11 Dividends used In this title (except in paragraph (10) of subdivl- 12 Definition sion (a) of Section 234) means (1) any distribution 13 made by a corporation, other than a personal serv- 14 Ice corporation, to Its shareholders or members, 15 whether In cash or In other property or In stock 16 of the corporation, out of Its earning or profits 17 accumulated since February 28, 1913, or (2) any such IB distribution made by a personal service corporation 19 out of Its earnings or profits accumulated since Feb- 20 ruary 28, 1913, and prior to January 1, 1918. 21 (b) Any distribution shall be deemed to have been 22 made from earnings or profits unless all earnings and 23 profits have first been distributed. Any distribution 24 Dividends Paid made In the year 1918 or any year thereafter shall be 25 in Year 1918 deemed to have been made from earnings or profits 26 accumulated since February 28, 1913, or, in the , case of 27 a personal service corporation, from the most recently 28 accumulated earnings or profits; but any earnings or 29 profits accumulated prior to March 1, 1913, may be dis- 30 tributed in stock dividends or otherwise, exempt from 31 the tax, after the earnings and profits accumulated 32 since February 28, 1913, have been distributed. 33 (c) A dividend paid in stock of the corporation shall 34 Stock be considered income to the amount of the earnings 35 Dividends or profits distributed. Amounts distributed in the llq- 36 uidatlon of a corporation shall be treated as payments 37 in exchange for stock or shares, and any gain or profit 38 realized thereby shall be taxed to the distributee as 39 other gains or profits. 40 (d) If any stock dividend (1) Is received by a tax- 41 payer between January 1 and November 1, 1918, both 48 dates inclusive, or (2) Is during such period bona fide 43 authorized or declared, and entered on the books of the 44 corporation, and is received by a taxpayer after No- 45 vember 1, 1918, and before the expiration of thirty 46 days after the passage of this Act, then such dividend 47 shall, in the manner provided in Section 206, be taxed to 48 the recipient at the rates prescribed by law for the years 49 in which the corporation accumulated the earnings or 50 profits from which such dividend was paid, but the 51 dividend shall be deemed to have been paid from the 52 most recently accumulated earnings or profits. 53 (e) Any distribution made during the first sixty days 54 Dividends Paid of any taxable year shall be deemed to have been made 55 in First 60 from earnings or profits accumulated during preceding 56 Days of taxable years; but any distribution made during the 57 Taxable Tear remainder of the taxable year shall be deemed to have 58 53 1 been made from earnings or profits accumulated be- 2 tween the close of the preceding taxable year and the 8 date of distribution, to the extent of such earnings or 4 profits, and if the books of the corporation do not show 6 the amount of such earnings or profits, the earnings or • profits for the accounting period within which the dls- 7 tributlon was made shall be deemed to have been ac- 8 cumulated ratably during such period. Gain or Loss Property Ac- quired Before Mar. 1, 1913 Property Ac- quired Since Mar. 1, 1913 Exchange of Property Reorganization, Consolidation Inventories 37 40 41 4M 43 44 45 46 47 48 49 60 51 52 53 54 65 56 67 Basis for Determining' Gain or Iioss. SECTION 202. (a) That for the purpose of ascer- taining: the gain derived or loss sustained from the sale or other disposition of property, real, personal, or mixed, the basis shall be — (1) In the case of property acquired before March 1, 1913, the fair market price or value of such property as of that date; and (2) In the case of property acquired on or after that date, (a) the cost thereof; or (b) the Inventory value, if the inventory is made in accordance with section 203. (b) When property is exchanged for other property, the property received in exchange shall for the pur- pose of determining gain or loss be treated as the equivalent of cash to the amount of its fair market value, if any; but when in connection with the reor- ganization, merger, or consolidation of a corporation a person receives in place of stock or securities owned by him new stock or securities of no greater aggre- gate par or face value, no gain or loss shall be deemed to occur from the exchange, and the new stock or se- curities received shall be treated as taking the place of the stock, securities, or property exchanged. When in the case of any such reorganization, merger or consolidation the aggregate par or face value of the new stock or securities received is in excess of the ag- gregate par or face value of the stock or securities exchanged, a like amount in par or face value of the new stock or securities received shall be treated as tak- ing the place of the stock or securities exchanged, and the amount of the excess In par or face value shall be treated as a gain to the extent that the fair market value of the new stock or securities Is greater than the cost (or If acquired prior to March 1, 1913, the fair market value as of that date) of the stock or securities exchanged. Inventories. SECTION 203. That whenever in the opinion of the Commissioner the use of inventories is necessary in order clearly to determine the Income of any taxpayer. Inventories shall be taken by such taxpayer upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice In the trade or business and as most clearly reflecting the Income. 54 Net ZiOBsei. 1 2 SECTION 204. (a) That as used in this section the 3 "Net Losses" term "net loss" refers only to net losses resulting from 4 Definition either (1) the operation of any business regularly car- 5 rled on by the taxpayer, or (2) the bona fide sale by 6 the taxpayer of plant, buildings, machinery, equipment 7 or other facilities, constructed, installed or acquired by 8 the taxpayer on or after April 6, 1917, for the produc- 9 tion of articles contributing to the prosecution of the 10 present war; and when so resulting means the excess 11 of the deductions allowed by law (excluding in the 12 case of corporations amounts allowed as a deduction 13 under paragraph (6) of subdivision (a) of section 234) 14 over the sum of the gross income plus, any interest 15 received free from taxation both under this title and 16 under Title III. 17 (b) If for any taxable year beginning after October 18 Readjustment 31, 1918, and ending prior to January 1, 1920, it appears 19 of Losses upon the production of evidence satisfactory to the 20 Commissioner that any taxpayer has sustained a net 21 loss, the amount of such net loss shall under regula- 22 tions prescribed by the Commissioner with the approval 23 of the Secretary be deducted from the net income of 24 the taxpayer for the preceding taxable year; and the 25 taxes imposed by this title and by Title III for such 26 preceding taxable year shall be redetermined accord- 27 ingly. Any amount found to be due to the taxpayer 28 upon the basis of such redetermination shall be credited 29 or refunded to the taxpayer in accordance with the 30 provisions of section 252. If such net loss is in excess 31 of the net income for such preceding taxable year, the 32 amount of such excess shall under regulations pre- 33 scribed by the Commissioner with the approval of the 34 Secretary be allowed as a deduction in computing the 35 net income for the succeeding taxable year. 36 (c) The benefit of this section shall be allowed to the 37 Benefits members of a partnership and the beneficiaries of an 38 Allowed estate or trust under regulations prescribed by the 39 Parnerships Commissioner with the approval of the Secretary. 40 and Estates 41 Fiscal Year With Different Rates. 42 43 SECTION 205. (a) That if a taxpayer makes return 44 Fiscal Year for a fiscal year beginning in 1917 and ending in 1918, 45 Other Than his tax under this title for the first taxable year shall 46 Calendar be the sum of: (1) The same proportion of a tax for 47 Year for the entire period computed under Title I of the Revenue 48 1917-18 Act of 1916 as amended by the Revenue Act of 1917 and 49 under Title I of the Revenue Act of 1917, which the 60 portion of such period falling within the calendar year 51 1917 is of the entire period, and (2) the same propor- 52 tion of a tax for the entire period computed under thiE 63 title at the rates for the calendar year 1918 which the 64 portion of such period falling within the calendar year 55 1918 is of the entire period: Provided, That in the case 56 of a personal service corporation the amount to be paid 57 shall be only that specified in clause (1). 68 How Tax 1 Any amount heretofore or hereafter paid on account Rate Is 2 of the tax imposed for such fiscal year by Title I of the Apportioned 3 Revenue Act of 1916 as amended by the Revenue Act 4 of 1917, and by Title I of the Revenue Act of 1917, 6 shall be credited towards the payment of the tax im- 6 posed for such fiscal year by this Act, and if the amount 7 so paid exceeds the amount of such tax imposed by this 8 Act, or, in the case of a personal service corporation, 9 the amount specified in clause (1), the excess shall be 10 credited or refunded in accordance with the provl- 11 sions of section 252. Fiscal Year 12 (b) If a taxpayer makes a return for a fiscal year 1918-19 13 beginning in 1918 and ending In 1919, the tax under 14 this title for such fiscal year shall be the sum of: (1) 15 the same proportion of a tax for the entire period com- 16 puted under this title at the rates specified for the 17 calendar year 1918 which the portion of such period 18 falling within the calendar year 1918 is of the entire 19 period, and (2) the same proportion of a tax for the 20 entire period computed under this title at the ratea 21 specified for the calendar year 1919 which the portion 22 of such period falling within the calendar year 1919 is 23 of the entire period. Partnerships 24 (c) If a fiscal year of a partnership begins in 1917 Fiscal Year 25 and ends in 1918 or begins in 1918 and ends in 1919, Other Than 26 then notwithstanding the provisions of subdivision (b) Calendar 27 of section 218, (1) the rates for the calendar year dur- Year 28 ing which such fiscal year begins shall apply to an 29 amount of each partner's share of such partnership 30 net income (determined under the law applicable to 31 such year) equal to the proportion which the part of 35 such fiscal year falling within such calendar year 33 bears to the full fiscal year, and (2) the rates for the 34 calendar year during which such fiscal year ends shall 30 apply to an amount of each partner's share of such 36 partnership net income (determined under the law ap- 37 plicable to such calendar year) equal to the propor- 38 tion which the part of such fiscal year falling within 39 such calendar year bears to the full fiscal year: Pro- 40 vided. That in the case of a personal service corporation 41 with respect to a fiscal year beginning in 1917 and end- 48 ing in 1918, the amount specified in clause (1) shall 43 not be subject to normal tax. 44 Income Subject 45 Parts of Income Subject to Bates for Different Years, to Rates for 46 Different 47 SECTION 206. That whenever parts of a taxpayer's Years 48 income are subject to rates for different calendar years, 49 the part subject to the rates for the most recent cal- 50 endar year shall be placed in the lower brackets of 81 the rate schedule provided in this title, the part sub- 53 ject to the rates for the next preceding calendar year 53 shall be placed in the next higher brackets of the rate 54 schedule applicable to that year, and so on until the 55 entire net income has been accounted for. In determin- 58 ing the Income, any deductions, exemptions or credits 57 of a kind not plainly and properly chargeable against 58 the income taxable at rates for a preceding year shall 56 first be applied against the income subject to rates for 1 the most recent calendar year; but any balance thereof 2 shall be applied against the income subject to the rates 3 of the next preceding year or years until fully allowed. 4 5 6 PART XZ.— ZNDIVIDVAl^S. 7 8 Normal Tax. 9 10 SECTION 210. That, in lieu of the taxes Imposed by 11 Individuals subdivision (a) of section 1 of the Revenue Act of 1916 12 Normal Tax and by section 1 of the Revenue Act of 1917, there shall 13 Year 1918 be levied, collected, and paid for each taxable year upon 14 the net income of every individual a normal tax, at the 15 following rates: ^ IS (a) For the calendar year 1918, 12 per centum of the IV amount of the net Income in excess of the credits pro- 13 vided in section 216: Provided, That in the case of a 19 citizen or resident of the United States the rate upon 23 the first $4,000 of such excess amount shall be 6 per 21 centum; 22 (b) For each calendar year thereafter, 8 per centum 23 Year 1919 an I of the amount of the net income in excess of the credits 24 Thereafter provided in section 216: Provided, That in the case of 25 a citizen or resident of the United States the rate upon 26 the fix'st $4,000 of such excess amount shall be 4 per 27 centum. 28 29 Surtax. 30 31 SECTION 211. (a) That, in lieu of the taxes Im- 32 Surtax posed by subdivison (b) of section 1 of the Revenue 33 Schedules Act of 1916 and by section 2 of the Revenue Act of 34 of Rates 1917, but in addition to the normal tax imposed by sec 35 tion 210 of this Act, there shall be levied, collected, and 36 paid for each taxable year upon the net income of every 37 individual, a surtax equal to the sum of the followlng-j 38 1 per centum of the amount by which the net in- 39 come exceeds $5,000 and does not exceed $6,000; 40 2 per centum of the amount by which the net Incomtj 41 exceeds $6,000 and does not exceed $8,000; 42 3 per centum of the amount by which the net income 43 exceeds $8,000 and does not exceed $10,000; 44 4 per centum of the amount by which the net Income 45 exceeds $10,000 and does not exceed $12,000; 46 5 per centum of the amount by which the net income 47 exceeds $12,000 and does not exceed $14,000; 43 6 per centum of the amount by which the net Income 49 exceeds $14,000 and does not exceed $16,000; 50 7 per centum of the amount by which the net income 51 exceeds $16,000 and does not exceed $18,000; 52 8 per centum of the amount by which the net Income 53 exceeds $18,000 and does not exceed $20,000; 54 9 per centum of the amount by which the net Income 55 exceeds $20,000 and does not exceed $22,000; 56 10 per centum of the amount by which the net Income 57 exceeds $22,000 and does not exceed $24,000; 58 57 1 11 per centum of the amount by wliich the net income 2 exceeds $24,000 and does not exceed $26,000; 3 12 per centum of the amount by which the net income 4 exceeds $26,000 and does not exceed $28,000; 5 13 per centum of the amount by which the net Income 6 exceeds $28,000 and does not exceed $30,000; 7 14 per centum of the amount by which the net income 8 exceeds $30,000 and does not exceed $32,000; 9 15 per centum of the amount by whicli the net income 10 exceeds $32,000 and does not exceed $34,000; 11 16 per centum of the amount by which the net income 12 exceeds $34,000 and does not exceed $36,000; 13 17 per centum of the amount by whicli the net income 14 exceeds $36,000 and does not exceed $38,000; 15 18 per centum of the amount by which the net income 16 exceeds $38,000 and does not exceed $40,000; 17 19 per centum of the amount by which the net income 18 exceeds $40,000 and does not exceed $42,000; 19 20 per centum of the amount by whicli the net income 20 exceeds $42,000 and does not exceed $44,000; 21 21 per centum of the amount by which the net income 22 exceeds $44,000 and does not exceed $46,000; 23 22 per centum of the amount by which the net income 24 exceeds $46,000 and does not exceed $48,000; 25 23 per centum of the amount by which the net income 26 exceeds $48,000 and does not exceed $50,000; 27 24 per centum of the amount by which the net income 28 exceeds $50,000 and does not exceed $52,000; 29 25 per centum of the amount by which the net income 30 exceeds $52,000 and does not exceed $54,000; 31 26 per centum of the amount by which the net income 32 exceeds $54,000 and does not exceed $56,000; 33 27 per centum of tlie amount by which the net income 34 exceeds $56,000 and does not exceed $58,000; 35 28 per centum of the amount by which the net income 36 exceeds $58,000 and does not exceed $60,000; 37 29 per centum of the amount by which the net Income 38 exceeds $60,000 and does not exceed $62,000; 39 30 per centum of the amount by which the net Income 40 exceeds $62,000 and does not exceed $64,000; 41 31 per centum of the amount by which the net income 42 exceeds $64,000 and does not exceed $66,000; '^ 32 per centum of the amount by w^hich the net income 44 exceeds $66,000 and does not exceed $68,000; 45 33 per centum of the amount by which the net income 46 exceeds $68,000 and does not exceed $70,000; 47 34 per centum of the amount by which the net income 48 exceeds $70,000 and does not exceed $72,000; 49 35 per centum of the amount by wliicli the net income 50 "xceeds $72,000 and does not exceed $74,000; 51 36 per centum of the amount by which the net income 52 exceeds $74,000 and does not exceed $76,000; 53 37 per centum of the amount by which the net income 54 exceeds $76,000 and does not exceed $78,000; 55 38 per centum of the amount by which the net income 56 exceeds $78,000 and does not exceed $80,000; B7 39 per centum of the amount by which the net income 5S exceeds $80,000 and does not exceed $82,000; 58 40 per centum of the amount by which the net Income "* exceeds $82,000 and does not exceed $84,000; 2 41 per centum of the amount by which the net income 3 exceeds 84,000 and does not exceed $86,000; 4 42 per centum of the amount by which the net Income 6 exceeds $86,000 and does not exceed $88,000; 6 43 per centum of the amount by whioh the net income 7 exceeds $88,000 and does not exceed $90,000; 8 44 per centum of the amount by which the net Income 9 exceeds $90,000 and does not exceed $92,000; 10 45 per centum of the amount by which the net Income 11 exceeds $92,000 and does not exceed $94,000; 12 46 per centum of the amount by which the net Income 13 exceeds $94,000 and does not exceed $96,000; 14 47 per centum of the amount by wliich the net income 15 exceeds $96,000 and does not exceed $98,000; 16 48 per centum of the amount by which the net Income 17 exceeds $98,000 and does not exceed $100,000; 18 52 per centum of the amount by which the net income 19 exceeds $100,000 and does not exceed $150,000; 20 56 per centum of the amount by which the net Income 21 exceeds $150,000 and does not exceed $200,000; 22 60 per centum of the amount by which the net income 23 exceeds $200,000 and does not exceed $300,000; 24 63 per centum of the amount by which the net income 25 exceeds $300,000 and does not exceed $500,000; 26 64 vev centum of the amount by which the net income 27 exceeds $500,000 and does not exceed $1,000,000; 28 65 per centum of the amount by which the net income 29 exceeds $1,000,000. 30 (b) In the case of a bona fide sale of mines, oil or 31 Limitation of gas wells, or any interest therein, where the principal 32 Surtax value of the property has been demonstrated by pros- 33 on Income pecting or exploration and discovery work done by the 34 from Mines, taxpayer, the portion of the tax imposed by this section 35 Oil and Gas attributable to such sale shall not exceed 20 per centum 36 of the selling price of such property or interest. 37 38 Net Income Defined. 39 40 SECTION 212. (a) That in the case of an individual 41 Net Income the term "net income" means the gross income as de- 42 Definition fined in section 213, less the deductions allowed by sec- 43 How tion 214. 44 Computed (b) The net income shall be computed upon the basis 45 of the taxpayer's annual accounting period (fiscal year 46 or calendar year, as the case may be) in accordance 47 with the method of accounting regularly employed in 48 keeping the books of such taxpayer; but if no such 49 method of accounting has been so employed, or if the 50 method employed does not clearly reflect the income, the 51 computation shall be made upon such basis and in such 52 manner as In the opinion of the Commissioner does 53 clearly reflect the income. If the taxpayer's annual 54 accounting period is other than a fiscal year as defined 55 in section 200 or if the taxpayer has no annual ac- 56 counting period or does not keep books, the net Income 57 shall be computed on the basis of the calendar year. B8 59 Change of Accounting Period G-roMS Xnoome Definition EKempt Income Life Insurance Policies Return of Premium Gifts and Bequests Interest from Obligations of State and Political Subdivisions Federal Farm Loans Obligation of United States 1 If a taxpayer changes his accounting period from 2 fiscal year to calendar year, from calendar year to fiscal 3 year, or from one fiscal year to another, the net Income 4 shall, with the approval of the Commissioner, be com- 6 puted on the basis of such new accounting period, sub- 6 ject to the provisions of section 226. 7 8 G-ros« Xncoxue Defined. 9 10 SECTION 213. That for the purposes of this title 11 (except as otherwise provided In section 233) the term 12 "gross income" — 13 (a) Includes gains, profits, and income derived from 14 salaries?, wag'es, or compensation for personal service 16 (including in the case of the President of the United 16 States, the judges of the Supreme and Inferior courts of IT the United States, and all other ofl^icers and employees, 18 Avhether elected or appointed, of the United States, 19 Alaska, Hawaii, or any political subdivision thereof, or 20 the District of Columbia, the compensation received as 21 such) of whatever kind and In whatever form paid, or 22 from professions, vocations, trades, businesses, com- 23 merce, or sales, or dealings In property, whether real or tf« personal, growing out of the ownership or use of or In- 25 terest in such property; also from interest, rent, divi- 26 dends, securities, or the transaction of any business 27 carried on for gain or profit, or gains or profits and In- 28 come derived from any source whatever. The 29 amount of all such items shall be Included in the gross 30 income for the taxable year In which received by the 31 taxpayer, unless, under methods of accounting per- 32 mitted under subdivision (b) of section 212, any such 33 amounts are to be properly accounted for as of a dlf- 34 ferent period; but 35 (b) Does not Include the following Items, which shall 36 be exempt from taxation under this title: 37 < I) The proceeds of life insurance v'olicies paid upon 38 the death of the insured to individual beneficiaries or 39 to the estate of the insured; 40 (2) The amount received by the insured as a return 41 of premium or premiums paid by him under life insur- 42 ance, endowment, or annuity contracts, either during 43 the term or at the maturity of the term mentioned In 44 the contract or upon surrender of the contract; 45 (3) The value of property acquired by gift, bequest, 46 devise, or descent (but the Income from such property 47 shall be included In gross Income) ; 48 (4) Interest upon (a) the obligations of a State, 49 Territory, or any political subdivision thereof, or the 60 District of Columbia; or (b) securities issued under the 51 provisions of the Federal Farm Loan Act of July 17, 52 1916; or (c) the obligations of the United States or Its 63 possessions; or (d) bonds Issued by the War Finance 64 Corporation: Provided, That every person owninq- any of 55 the obligations, securities or bonds enumerated In 66 clauses (a), (b), (o), and (d) shall, In the return re- 57 quii-ed by this title, submit a statement showing the 68 number and amount of such obligations, securities and GO bonds owned by him and the Income received there- 1 from, In such form and with such Information as the 2 Commissioner may require. In the case of obligations 3 of the United States issued after September 1, 1917, and 4 in the case of bonds issued by the War Finance Cor- 5 poratlon, the interest shall be exempt only If and to the 6 extent provided in the respective Acts authorizing the 7 issue thereof as amended and supplemented, and shall 8 be excluded from gross income only if and to the extent 9 it is wholly exempt from taxation to the taxpayer both 10 under this title and under Title III; 11 (5) The income of foreign governments received 12 Income of from investments in the United States in stocks, bonds, 13 Foreign or other domestic securities, owned by such foreign 14 Governments governments, or from interest on deposits in banks in 15 the United States of moneys belonging to such foreign 16 governments, or from any other source within the 17 United States; 18 (6) Amounts received, through accident or health in- 19 Accident, surance or under workmen's compensation acts, as 20 Health and compensation for personal injuries or sickness, plus the 21 Compensation amount of any damages received whether by suit or 22 Insurance agreement on account of such injuries or sickness; 23 (7) Income derived from any public utility or the 24 Income exercise of any essential governmental function and 25 Accruing accruing to any State, Territory, or the District of 26 to State Columbia, or any political subdivision of a State or 27 Territory, or income accruing to the government of 28 any possession of the United States, or any political 29 subdivision thereof. 30 Whenever any State, Territory, or the District of 31 Columbia, or any political subdivision of a State or 32 Territory, prior to September 8, 1916, entered in good 33 faith into a contract with any person, the object and 34 purpose of which is to acquire, construct, operate, or 35 maintain a public utility, no tax shall be levied under 36 the provisions of this title upon the income derived 37 from the operation of such public utility, so far as 38 the payment thereof will impose a loss or burden upon 39 suoh State, Territory, District of Columbia, or political 40 subdivision; but this provision is not intended to confer 41 upon such person any financial gain or exemption or to 42 relieve such person from the payment of a tax as pro- 43 vided for in this title upon the part or portion of such 44 income to which such person is entitled under such con- 45 tract; 46 (8) So much of the amount received during the pres- 47 Income of ent war by a person in the military or naval forces of 48 Military and the United States as salary or compensation io any 49 Naval Forces form from the United States for active services In such 50 forces as does not exceed $3,500. 51 (c) In the case of non-resident alien individuals, 52 Non-fes^L^eut gross income includes only the gross income from 53 Alien — Gro^s sources within the United States, including interest on 54 Income bonds, notes, or other interest-bearing obligations ojl 65 Defined residents, corporate or otherwise, dividends from resi- 56 dent corporations, and including all amounts received 57 (although paid under a contract for the sale of goods 58 61 1 or otherwise) representing profits on the manufacture a and disposition of goods within the United States. 3 4 6 6 Seductions AUowed. 7 Deductions 8 SECTION 214. (a) That In computing net income 9 there shall be allowed as deductions: Expenses 10 (1) All the ordinary and necessary expenses paid or II incurred during the taxable year in carrying on any la trade or business, including a reasonable allowance for 13 salaries or other compensation for personal services 14 actually rendered, and including rentals or other pay- 15 ments required to be made as a condition to the con- 16 tinued use or possession, for purposes of the trade or 17 business, of property to which the taxpayer has not 18 taken or is not taking title or In which he has no 19 equity; Interest on 20 (2) All interest paid or accrued within the taxable Indebtedness 21 year on indebtedness, except on indebtedness incurred 22 or continued to purchase or carry obligations or securi- 23 ties (other than obligations of the United States Issued 24 after September 24, 1917), the interest upon which Is 25 wholly exempt from taxation under this title as In- 26 come to the taxpayer, or, in the case of a non-resident 27 alien Individual, the proportion of such Interest which 28 the amount of his gross Income from sources within 29 the United States bears to the amount of his gross In- 30 come from all sources within and without the United 31 States; Taxes 32 (3) Taxes paid or accrued within the taxable year 33 imposed (a) by the authority of the United States, ex- 34 cept income, war profits and excess-profits taxes; or 35 (b) by the authority of any of its possessions, except 36 the amount of Income, war profits and excess-profits 37 taxes allowed as a credit under section 222; or (c) by 38 the authority of any State or Territory, or any county, 89 school district, municipality, or other taxing subdlvl- 40 sion of any State or Territory, not Including those 41 assessed against local benefits of a kind tending to in- 42 crease the value of the property assessed r or (d) In the 43 case of a citizen or resident of the United States, by the 44 authority of any foreign country, except the amount 45 of income, war-profits and excess-profits taxes allowed 46 as a credit under section 222; or (e) In the case of a 47 non-resident alien Individual, by the authority of any 48 foreign country (except income, war-profits and excess< 49 profits taxes, and taxes assesed against local benefits of 60 K. kind tending to increase the value of the property 51 assessed), upon property or business; Cosset 62 (4) Losses sustained during the taxable year and not XsOsses In 63 compensated for by Insurance or otherwise. If Incurred Trade 64 In trade or business; Losses Not 65 (5) Losses sustained during the taxable year and Connected 56 not compensated for by insurance or otherwise. If In- With 57 curred In any transaction entered into for profit, though Business 68 not connected with the trade or business; but In the case of a nonresident alien individual only as to such transactions within the United States; (6) Losses sustained during- the taxable year of prop- erty not connected with the trade or business (but in the case of a non-resident alien individual only prop- erty within the United States) if arising from fires, storms, shipwreck, or other casualty,- ^r from theft, and if not compensated for by insurance or otherwise; (7) Debts ascertained to be worthless and charged off within the taxable year; (8) A reasonable allowance for the exhaustion, wear and tear of property used in the trade or business, in- cluding a reasonable allowance for obsolescence; (9) In the case of buildings, machinexT. equipment, or other facilities, constructed, erected, installed, or acquired, on or after April 6, 1917, for the production of articles contributing to the prosecution of the pres- ent war, and in the case of vessels constructed or ac- quired on or after such date for the transportation of articles or men contributing to the pi'osecution of the present war, there shall be allowed a reasonable deduc- tion for amortization of such part of the cost of such facilities or vessels as has been borne by the tax- payer, but not again including any amount otherwise allowed under this title or previous Acts of Congi-est. as a deduction in computing net income. At any time within three years after the termination of the pres- ent war, the Commissioner may, and at the request ot the taxpayer shall, re-examine the return, and if he then finds as a result of an appi'aisal or from other evi- dence that the deduction originally allowed was incoi- rect, the taxes imposed by this title and by Title 111 for the year or years affected shall be redetermined; and the amount of tax due upon such redetermination, if any, shall be paid upon notice and demand by tlie collector, or the amount of tax overpaid, if any, shall be credited or refunded to the taxpayer in accordance with the provisions of section 252;. (10) In the case of mines, oil and gas wells, other natural deposits, and timber, a reasonable allowance for depletion and for depreciation of improvements, ac- cording to the peculiar conditions in each case, based upon cost including cost of development not otherwise deducted: Provided, That in the case of such properties acquired prior to March 1, 1913, the fair market value of the property (or the taxpayer's interest therein) on that date shall be taken in lieu of cost up to that date: Provided further, That in the case of mines, oil and gas wells, discovered by the taxpayer, on or after March 1, 1913, and not acquired as the result of purchase of a proven tract or lease, where the fair market vahu of the property is materially disproportionate to the cost, the depletion allowance .shall be based upon thf fair market value of the property at the date of the discovery, or within thirty days thereafter; such rea- sonable allowance in all the above cases to be made under rules and regulations to be prescribed by the Commissioner with the approval of the Secretary. In Losses from Fires, Storm, Shipwrecks Bad Debts Depreciation Depreciation of Property, etc. Constructed or Acquired in Connection With War Mines, Oil and Gas Wells- Depletion, Depreciation 63 1 the case of leases the deductions allowed by this para- 2 graph shall be equitably apportioned between the lessor 8 and lessee; Gifts to 4 (11) Contributions or gifts made within the taxable Religious, 6 year to corporations organized and operated exclusively Charitable, 6 for religious, charitable, scientific, or educational pur- Scientific and 7 poses, or for the prevention of cruelty to children or Educational 8 animals, no part of the net earnings of which inures to Corporations 9 the benefit of any private stockholder or individual, or 10 to the special fund for vocational rehabilitation au- 11 thorized by section 7 of the Vocational Rehabilitation la Act, to an amount not in excess of 15 per centum of 13 the taxpayer's net income as computed without the 14 benefit of this paragraph. Such contributions or gifts 15 shall be allowable as deductions only if verified under 16 rules and regulations prescribed by the Commissioner, 17 with the approval of the Secretary. In the case of a 18 nonresident alien individual this deduction shall be 19 allowed only as to contributions or gifts made to 20 domestic corporations, or to such vocational rehablli- 21 tation fund; Losses from 22 (12) (a) At the time of filing return for the taxable Decreased 23 year 1918 a taxpayer may file a claim in abatement Value of 24 based on the fact that he has sustained a substantial Inventory, 25 loss (whether or not actually realized by sale or other Rebates, etc. 26 disposition) resulting from any material reduction (not 27 due to temporary fluctuation) of the value of the In- 28 ventory for such taxable year, or from the actual pay- 29 ment after the close of such taxable year of rebates 30 In pursuance of contracts entered into during such year 31 upon sales made during such year. In such case pay- 32 ment of the amount of the tax covered by such claim 33 shall not be required until the claim is decided, but the 34 taxpayer shall accompany his claim with a bond In 35 double the amount of the tax covered by the claim, with 36 sureties satisfactory to the Commissioner, conditioned 37 for the payment of any part of such tax found to be 38 due, with Interest. If any part of such claim Is dis- 89 allovved then the remainder of the tax due shall on 40 notice and demand by the collector be paid by the tax- 41 payer with Interest, at the rate of 1 per centum per 42 month from the time the tax would have been due had 48 no such claim been filed. If it Is shown to the satls- 44 faction of the Commissioner that such substantial less 46 has been sustained, then in computing the tax imposed 46 by this title the amount of such loss shall be deducted 47 from the net income, (b) If no such claim Is filed, but 48 it is shown to the satisfaction of the Commissioner that 40 during the taxable year 1919 the taxpayer has sus- 50 tained a substantial loss of the character above de- 61 scribed then the amount of such loss shall be deducted 62 from the net income for the taxable year 1918 and the 63 tax imposed by this title for such year shall be re- Non-resident 54 determined accordingly. Any amount found to be due Alien 55 to the taxpayer upon the basis of such redetermination Individuals — 66 shall be credited or refunded to the taxpayer In ac- Deductions 57 cordance with the provisions of Section 252. Allowed 68 (b) In the case of a nonresident alien individual the 64 deductions allowed in paragraphs (1), (4), (7), (8), (9), 1 (10), (12) and clause (e) of paragraph (3), of subdivi- 2 sion (a) shall be allowed only if and to the extent that G they are connected with income arising from a source 4 within the United States; and the proper apportionment 5 and allocation of the deductions with respect to sources 6 of income within and without the United States shall be 7 determined under rules and regulations' prescribed by 8 the Commissioner with the approval of the Secretary. 9 10 Ztems Not Deductible. 11 12 SECTION 215. That in computing net income no 13 Items Not deduction shall in any case be allowed in respect of — 14 Deductible (a) Personal, livingr, or family expenses; 15 (b) Any amount paid out for new buildings or for 16 permanent improvements or betterments made to in- 17 crease the value of any property or estate; 18 (c) Any amount expended in restoring property or in 19 making good the exhaustion thereof for which an al- 20 lowance is or has been made; or 21 (d) Premiums paid on any life insurance policy cov- 22 ering the life of any officer or employee, or of any per- 23 son financially interested in any trade or business car- 24 Tied on by the taxpayer, when the taxpayer is directly 25 or indirectly a beneficiary under such policy, 26 27 Ci'edits Allowed. 28 29 SECTION 216. That for the purpose of the normal 30 Credits tax only there shall be allowed the following credits: 31 Allowed — (a) The amount received as dividends from a cor- 32 Dividends poration which is taxable under this title upon its 33 net income, and amounts received as dividends from a 34 personal service corporation out of earnings or profits 35 upon which income tax has been imposed by Act of 36 Congress; 37 (b) The amount received as interest upon obligations 38 Obligations of of the United States and bonds issued by the War 39 U. S. — ^When Finance Corporation, which is Included in gross income 40 under section 213; 41 (c) In the case of a single person, a personal ex- 42 Personal emptlon of $1,000, or in the case of the head of a 43 Exemption family or a married person living with husband or wife, 44 a personal exemption of $2,000. A husband and wife 46 living together shall receive but one personal exemption 46 of $2,000 against their aggregate net income; and In 47 case they make separate returns, the personal ex- 48 emption of $2,000 may be taken by either or divided 49 between them; 60 (d) $200 for each person (other than husband or 61 wife) dependent upon and receiving his chief support 62 from the taxpayer, if such dependent person Is under 53 eighteen years of age or is incapable of self-support 54 because mentally or physically defective. 55 (e) In the case of a nonresident alien individual who 56 Non-resident Is a citizen or subject of a country which Imposes an 57 Aliens Income tax, the credits allowed In subdivisions (c) and 68 65 1 (d) shall be allowed only If such country allows a a similar credit to citizens of the United States not reald- 3 Ing in such country. Non-resident Aliens — Deductions and Credits Allowed Partnerships and Personal Service Corporations Fiscal Year Other Than Calendar Year 6 Nonresident Aliens — Allowance of Dednctlons and 6 Credits. 7 8 SECTION 217. That a nonresident alien individual 9 shall receive the benefit of the deductions and credits 10 allowed in this title only by filing or causing to be 11 filed with the collector a true and accurate return of 12 his total income received from all sources corporate or 13 otherwise in the United States, in the manner pre- 14 scribed by this title, including therein all the informa- 16 tion which the Commissioner may deem necessary for 16 the calculation of such deductions and credits: Pro- 17 vided, That the benefit of the credits allowed in sub- 18 divisions (c) and (d) of section 216 may, in the dis- 19 cretion of the Commissioner, and except as otherwise 20 provided in subdivision (e) of that section, be received ai by filing a claim therefor with the withholding agent. 22 In case of failure to file a return, the collector shall 23 collect the tax on such income, and all property be- 24 longing to such nonresident alien individual shall be 25 liable to distraint for the tax. 26 27 Partnerships and Personal Service Corporations. 28 29 SECTION 218. (a) That individuals carrying on 30 business in partnership shall be liable for Income tax 31 only in their individual capacity. There shall be In- 32 eluded in computing the net income of each partner 38 his distributive share, whether distributed or not, of 34 the net income of the partnership for the taxable year, 35 or, if his net income for such taxable year is computed 36 upon the basis of a period different from that upon the 37 basis of which the net income of the partnership is 38 computed, then his distributive share of the net income 89 of the partnership for any accounting period of the 40 partnership ending within the fiscal or calendar year 41 upon the basis of which the partner's net income is 42 computed. 43 The partner shall, for the purpose of the normal 44 tax, be allow^ed as credits, in addition to the credits 45 allowed to him under section 216, his proportionate 46 share of such amounts specified in subdivisions (a) and 47 (b) of section 216 as are received by the partnership. 48 (b) If a fiscal year of a partnership ends during a 49 calendar year for which the rates of tax differ from 50 those for the preceding calendar year, then (1) the 51 rates for such preceding calendar year shall apply to 52 an amount of each partner's share of such partnership 53 net Income equal to the proportion which the part of 54 such fiscal year falling within such calendar year bears 55 to the full fiscal year, and (2) the rates for the cal- 56 endar year during which such fiscal year ends shall 57 apply to the remainder. 58 (c) In the case of an individual member of a part- 66 nership which makes return for a fiscal year beginning 1 in 1917 and ending in 1918, his proportionate share of 2 any excess profits tax imposed upon the partnership 3 under the Revenue Act of 1917 with respect to that 4 part of such fiscal year falling in 1917, shall, for the a the purpose of determining the tax imposed by this C title, be credited against that portion of the net income 7 embi-aced in his personal return for the taxable year 8 1918 to which the rates for 1917 apply. 9 (d) The net income of the partnership shall be com- 10 Partnership puted in the same manner and on the same basis as 11 Income — provided in section 212, except that the deduction 12 How provided in paragraph (11) of subdivision (a) of sec- 13 Computed tion 214 shall not be allowed. 14 (e) Personal service corporations shall not be sub- 15 Personal ject to taxation under this title, but the individual 16 Service stockholders thereof shall be taxed in the same manner 17 Corporation — as the members of partnerships. All the provisions 13 Individual of this title relating to partnerships and the members 19 Stockholders thereof shall so far as practicable apply to personal 20 Taxed the service corporations and the stockholders thereof: 21 Same as Provided, That for the purpose of this subdivision 22 Partnerships amounts distributed by a personal service corporation 23 during Its taxable year shall be accounted for by the 24 distributees; and any portion of the net Income remain- 25 ing undistributed at the close of its taxable year shall £6 be accounted for by the stockholders of such corpora- 27 tion at the close of its taxable year in proportion to £3 their respective shares. £9 Estates and Trusts. 31 S2 SECTION 219. (a) That the tax Imposed by sections 33 Estates and 210 and 211 shall apply to the Income of estates or of 34 Trusts — any kind of property held In trust, inoluding — 35 Taxable (1) Income received by estates of deceased persons 36 Income during the period of administration or settlement of 37 Defined the estate; 33 (2) Income accumulated in trust for the benefit of 39 unborn or unascertained persons or persons with con- 40 tlngent Interests; 41 (3) Income held for future distribution under the 43 terms of the will or trust; and 43 (4) Income which is to be distributed to the bene- 44 flciaries periodically, whether or not at regular Inter- 15 vals, and the Income collected by a guardian of an -13 infant to be held or distributed as the court may ^I7 direct. 43 (b) The fiduciary shall be responsible for making 49 Returns — the return of Income for the estate or trust for which 50 Computation he acts. The net Income of the estate or trust shall 51 of locome be computed In the same manner and on the same basis 52 as provided In section 212, except that there shall also bS be allowed as a deduction (in lieu of the deduction au- £4 thorlzed by paragraph (11) of subdivision (a) of sec- £;;3 tion 214) any part of the gross income which, pursuant £G to the terms of the will or deed creating the trust, is 57 during the taxable year paid to or permanently set 53 67 1 aside for the United States, any State, Territory, or any 2 political subdivision thereof, or the District of Co- 3 lumbia, or any corporation organized and operated ex- 4 clusively for religious, charitable, scientific, or educa- 5 tional purposes, or for the prevention of cruelty to 6 children or animals, no part of the net earnings of 7 which inures to the benefit of any private stockholder 8 or Individual; and in cases under paragraph (4) of sub- 9 division (a) of this section the fiduciary shall include 10 in the return a statement of each beneficiary's dls- 11 tributive share of such net income, whether or not dis- 12 tributed before the close of the taxable year for which 13 the return is made. Tax to Be Paid 14 (c) In cases under paragraph (1), (2), or (3) of by Fiduciary 15 subdivision (a) the tax shall be imposed upon the 16 net Income of the estate or trust and shall be paid 17 by the fiduciary, except that in determining the net 18 Income of the estate of any deceased person during 19 the period of administration or settlement there may be 20 deducted the amount of any income properly paid or ai credited to any legatee, heir or other beneficiary. In 22 such cases the estate or trust shall, for the purpose of 23 the normal tax, be allowed the same credits as are 2^ allowed to single persons under section 216. Income of 25 (d) In cases under paragraph (4) of subdivision Estate 26 (a), and in the case of any income of an estate during During 27 the period of administration or settlement permitted Period of Ad- 28 by subdivision (c) to be deducted from the net income ministration 29 upon which tax is to be paid by the fiduciary, the tax 30 shall not be paid by the fiduciary, but there shall be 31 Included in computing the net income of each bene- 38 ficiary his distributive share, whether distributed or 33 not, of the net income of the estate or trust for the 34 taxable year, or, if his net Income for such taxable 35 year Is computed upon the basis of a period different 38 from that upon the basis of which the net income of 37 the estate or trust is computed, then his distributive 38 share of the net income of the estate or trust for any 89 accounting period of such estate or trust ending within 40 the fiscal or calendar year upon the basis of which 41 such beneficiary's net income is computed. In such 42 cases the beneficiary shall, for the purpose of the 43 normal tax, be allowed as credits In addition to the 44 credits allowed to him under section 216, his propor- 46 tlonate share of such amounts specified In subdivisions 46 (a) and (b) of section 216 as are received by the 47 estate or trust. 48 49 Profits of CorporationB Taza1)l« to Stockholders. 60 Accumulated 51 SECTION 220. That if any corporation, however Profits of 52 created or organized. Is formed or availed of for the Corporation 53 purpose of preventing the Imposition of the surtax Taxable to 54 upon its stockholders or members through the medium Stockholders 53 of permitting its gains and profits to accumulate 56 instead of being divided or distributed, such corpora- 57 tion shall not be subject to the tax Imposed by section 68 230, but the stockholders or jnembers thereof shall be 68 subject to taxation under this title in the same manner 1 as provided in subdivision (e) of section 218 in the case 2 of stoclcholders of a personal service corporation, except 3 that the tax imposed by Title III shall be deducted 4 from the net income of the corporation before the com- 5 putation of the pz'oportionate share of each stockholder 6 or member. The fact that any corporation is a mere 7 holding company, or that the gains and profits 8 are permitted to accumulate beyond the reasonable 9 needs of the business, shall be prima facie evidence of 10 a purpose to escape the surtax; but the fact that the 11 gains and profits are in any case permitted to accumu- 13 late and become surplus shall not be construed as 13 evidence of a purpose to escape the tax in such case 14 unless the Commissioner certifies that In his opinion 15 such accumulation Is unreasonable for the purposes 16 of the business. When requested by the Commissioner. 17 or any collector, every corporation shall forward to 18 him a correct statement of such gains and profits and 19 the names and addresses of the individuals or share- 20 holders who would be entitled to the same if divided 21 or distributed, and of the amounts that would be 22 payable to each. 23 24 Payment of Tax at Source. 25 26 SECTION 221. (a) That all Individuals, corpora- 27 PaymentB of tions and partnerships, in whatever capacity acting. 28 Tax at including lessees or mortgagors of real or personal 29 Source — Tax property, fiduciaries, employers, and all ofEicers and 30 on Income of employees of the United States, having the control, 31 Non-resident receipt, custody, disposal, or payment, of Interest, rent, 32 Alien salaries, wages, premiums, annuities, compensations, 33 Individual remunerations, emoluments, or other fixed or determin- 34 to Be able annual or periodical gains, profits, and Income, 35 Withheld of any nonresident alien individual (other than Income 36 received as dividends from a corporation which If 37 taxable under this title upon Its net Income, shall (ex- 38 cept in the cases provided for in subdivision (b) and 39 except as otherwise provided In regulations prescribed 40 by the Commissioner under section 217) deduct and 41 withhold from such annual or periodical gains, profits^ 42 and income a tax equal to 8 per centum thereof: Pro- 43 vided. That the Commissioner may authorize such tax 44 to be deducted and withheld from the interest upon 45 any securities the owners of which are not known tc 46 the withholding agent. 47 (b) In any case where bonds, mortgages, or deeds of 48 Bonds trust, or other similar obligations of a corporation 49 Oontaiaxingr contain a contract or provision by which the obligor 50 Tax-free agrees to pay any portion of the tax Imposed by this 51 Covenant- title upon the obligee, or to reimburse the obligee for 52 Tax on any portion of the tax, or to pay the interest without 53 Interest at deduction for any tax which the obligor may be re- 54 Rate of 2% quired or permitted to pay thereon or to retain there- 55 to Be from under any law of the United States, the obligor 56 Withheld and shall deduct and withhold a tax equal to 2 per centum 67 Paid for of the Interest upon such bonds, mortgages, deeds of 58 Citizens and 69 Residents, 1 Partnerships, 2 Nonresident 3 and Allen 4 inaividuals 6 6 7 i> 9 10 11 12 13 1-5 15 16 17 Returns of 18 Taxes 19 Withheld 20 21 22 23 24 25 20 27 28 Credit for Tax 29 Withheld 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 48 Credit for 47 Taxes — 48 Citizen 49 ro PI na C3 Resident 64 55 F .' Allen B7 Resident 58 trust, or other obligations, whether such interest is payable annually or at shorter or longer periods and whether payable to a nonresident alien individual or to an individual citizen or resident of the United States or to a partnership: Provided, That the Commissioner may authorize such tax to be deducted and withheld in the case of Interest upon any such bonds, mort- gages, deeds of trust or other obligations, the owners of which are not known to the withholding agent. Such deduction and withholding shall not be required in the case of a citizen or resident entitled to receive such interest, if he files v/ith the withholding agent on or before February 1, a signed notice in writing claiming the benefit of the credits provided in subdivisions (c) and (d) of section 216; nor in the case of a nonresident alien Individual if so provided for In regulations pre- scribed by the Commissioner under section 217. (c) Every individual, corporation, or partnership re- quired to deduct and withhold any tax under this sec- tion shall make return thereof on or before March first of each year and shall on or before June 15th pay the tax to the oflicial of the United States Govern- ment authorized to receive it. Every such individual, corporation, or partnership is hereby made liable for such tax and is hereby indemnified against the claims and demands of any individual, corporation, or part- nership for the amount of any payments made In ac- cordance with the provisions of this section. (d) Income upon which any tax is required to be withheld at the source under this section shall be In- cluded In the return of the recipient of such income, but any amount of tax so withheld shall be credited against the amount of income tax as computed In such return. (e) If any tax required under this section to be de- ducted and withheld is paid by the recipient of the income, it shall not be re-collected from the withhold- ing agent; nor in cases in which the tax is so paid shall any penalty be imposed upon or collected from the recipient of the income or the withholding agent for failure to return or pay the same, unless such failure was fraudulent and for the purpose of evading payment. Credit for Taxes. SECTION 222. (a) That the tax computed under Part II of this title shall be credited with: (1) In the case of a citizen of the United States, the amount of any Income, war-profits and excess-profits taxes paid during the taxable year to any foreign country, upon income derived from sources therein, or to any possession of the United States; and (2) In the case of a resident of the United States, the amount of any such taxes paid during the taxable year to any possession of the United States; and (3) In the case of an alien resident of the United States who Is a citizen or subject of a foreign country. 70 the amount of any such taxes paid or accrued during tlie taxable year to such country, upon income derived from sources therein, if such country, in imposing such taxes, allows a similar credit to citizens of the United States residing in such country; and (4) In the case of any such individual who is a mem- ber of a partnership or a beneficiary of an estate or trust, his proportionate share of such" taxes of the 8 partnership or the estate or trust paid during the tax- 9 able year to a foreign country or to any possession of 10 the United States, as the case n»ay be. H (b) If accrued taxes when paid differ from the 12 amounts claimed as credits by the taxpayer, or if any 13 tax paid is refunded in whole or in part, the taxpayer 14 shall notify the Commissioner who shall redetermine 15 the amount of the tax due under Part II of this title 16 for the year or years affected, and the amount of 17 tax due upon such redetermination, if any, shall be 18 paid by the taxpayer upon notice and demand by the 19 collector, or the amount of tax overpaid, if any, shall 20 be credited or refunded to the taxpayer in accordance 21 with the provisions of Section 252. In- the case of 22 such a tax accrued but not paid, the Commis«5ioner as 23 a condition precedent to the allowance of this credit 24 may require the taxpayer to give a bond with sureties 25 satisfactory to and to be approved by the Commissioner 26 in such penal sum as the Commissioner may require, 27 conditioned for the payment by the taxpayer of any 28 amount of tax found due upon any such redetermine • 29 tion; and the bond herein prescribed shall contain 30 such further conditions as the commissioner may re- 31 quire. 32 (c) These credits shall be allowed only If the tax- 33 payer furnishes evidence satisfactory to the Commls- 34 sioner showing the amount of Income derived from 35 sources within such foreign country or such possession 36 of the United States, and all other information nece»- 37 sary for the computation of such credits. 38 39 40 41 Individual Retnrns. 42 43 SECTION 223. That every individual having a net 44 Income for the taxable year of $1,000 or over If single '^5 or if married and not living with husband or wife, 46 or of ?2,000 or over If married and living with hus- 47 band or wife, shall make under oath a return stating 48 specifically the items of his gross income and the 49 deductions and credits allowed by this title. If a hus- BO band and wife living together have an aggregate net 61 income of $2,000 or over, each shall make such a return 52 unless the income of each Is included In a single joint 53 return. 54 If the taxpayer Is unable to make his own return, 55 the return shall be made by a duly authorized agent 56 or by the guardian or other person charged with the 57 care of the person or property of such taxpayer. 58 Individual Partner, Beneficiary When Amount of Tax Differs From Amount Claimed as Credit Satisfactory Evidence Required Retnms — Individual Return by Agent fc^ ca i 71 Partnership Returns. 1 2 Partnership 3 SECTION 224. That every partnership shall make Returns 4 a return for each taxable year, stating specifically the 6 Items of its gross Income and the deductions allowed 6 by this title, and shall include in the return the names 7 and addresses of the Individuals who would be entitled 8 to share in the net income if distributed and the 9 amount of the distributive share of each individual. 10 The return shall be sworn to by any one of the 11 partners. 12 Fiduciary Returns. 13 Fiduciary 14 SECTION 225. That every fiduciary (except re- Returns 15 ceivers appointed by authority of law in possession of 16 part only of the property of an individual) shall make 17 under oath a return for the individual, estate or trust 18 for which he acts (1) if the net income of such 19 individual is $1,000 or over if single or if married and 20 not living with husband or wife, or $2,000 or over if 21 married and living with husband or wife, or (2) if tlie 22 net Income of such estate or trust is $1,000 or over 23 or if any beneficiary of such estate or trust is a non- 24 resident alien, stating specifically the items of the 26 gross income and the deductions and credits allowed 28 by this title. Under such regulations as the Com- 27 missioner with the approval of the Secretary may 28 prescribe, a return made by one of two or more joint 29 ^duciaries and filed in the office of the collector of the 30 Ustrict where such fiduciary resides shall be a suffi- 31 cient compliance with the above requirement. The 32 fiduciary shall make oath that he has sufficient knowl- 33 edge of the affairs of such individual, estate or trust 34 to enable him to make the return, and that the same 35 is, to the best of his knowledge and belief, true and 36 correct. 37 Fiduciaries required to make returns under this Act 38 shall be subject to all the provisions of this Act 39 which apply to individuals. 41 Returns When Accounting' Period Changed. 42 Return When 43 SECTION 226. Tliat if a taxpayer, with the ap- Accounting 44 proval of the Commissioner, changes the basis of corn- Period 45 puting net income from fiscal year to calendar year Changed '^" a separate return shall be made for the period be- 47 Lween the close of the last fiscal year for which return 48 was made and the following December 31. If the 49 change is from calendar year to fiscal year, a separate 50 return shall be made for the period between the close 51 of the last calendar year for which return was made 52 and the date designated as the close of the fiscal year. 53 If the change is from one fiscal year to another fiscal 54 year a separate return shall be made for the period 55 between the close of the former fiscal year and the 56 date designated as the close of the new fiscal year. If 57 V taxpayer making his first rettirn for income tax keeps 58 his accounts on the basis of a -fiscal year he shall make 72 a separate return for the period between the beginning 1 of the calendar year in whicli such fiscal year ends 2 and the end of such fiscal year. 3 In all of the above cases the net Income shall be 4 computed on the basis of such period for which sep- 5 arate return Is made,, and the tax shall be paid thereon 6 at the rate for the calendar year in which such period 7 is included; and the credits provided in subdivisions 8 (c) and (d) of section 216 shall be reduced respec- 9 tively to amounts which bear the same ratio to the 10 full credits provided in such subdivisions as the num- 11 ber of months in such period bears to twelve months. 12 18 Time and Place for Filing' Returns. 14 16 SECTION 227. (a) That returns shall be made on 16 Time nad or before the fifteenth day of the third month follow- 17 Place for ing the close of the fiscal year, or, if the return is 13 Filing made on the basis of the calendar year, then the return 19 Returns shall be made on or before the fifteenth day of March. 20 The Commissioner may grant a reasonable extension 21 of time for filing returns whenever in his judgment 22 good cause exists and shall keep a record of every 23 such extension and the reason therefor. Except in the 24 case of taxpayers who are abroad, no such extension 25 shall be for more than six months. 26 (b) Returns shall be made to the collector for the 27 district in which is located the legal residence or 28 principal place of business of the person making the_29 return, or, if he has no legal residence or principal 30 place of business in the United States, then to the 31 collector at Baltimore, Maryland. 32 33 Vnaerstatement in Returns. 34 35 SECTION 228. That if the collector or deputy col- SS Under- lector has reason to believe that the amount of any 37 statement in income returned is understated, he shall give due 38 Return notice to the taxpayer making the return to show 39 cause why the amount of the return should not De 40 increased, and upon proof of the amount understated, 43 may Increase the same accordingly. Such taxpayer 42 may furnish sworn testimony to prove any relevant 43 facts and if dissatisfied with the decision of the col^44 lector may appeal to the Commissioner for his de-45 clsion, under such rules of pi'ocedure a.s may be pre- 46 scribed by the Commissioner with the approval of 47 the Secretary. 48 49 PART ZIZ.— CORPORATIONS. 50 61 Tax on Corporations. 52 Corporations — 53 Taxes on SECTION 230. (a) That, In lieu of the taxes im- 54 posed by section 10 of the Revenue Act of 1916, as 55 amended by the Revenue Act of 1917, and by section 56 i of the Revenue Act of 1917, there shall be levied, 57 collected, and paid for each taxable year upon the net 58 ~ 73 , .. Year 1918 Year 1919 and Thereafter Systems Under Federal Control Exempt Corporations Labor, Agricultural Mutual Savings Banks Fraternal Organizations Building and Loan Cemetery Religious, Charitable Educational, etc. Chambers of Commerce, etc. Civic Leagues Clubs Insurance Telephone 1 income of every corporation a tax at the following 2 rates: . ■"*. ^iSPt 3 (1) For the calendar year 1918, 12 per centum of 4 the amount of the net Income in excess of the credits 5 provided In section 236; and 6 (2) For each calendar year thereafter, 10 per centum 7 of such excess amount. 8 (b) For the purposes of the Act approved March 21, 9 1918, entitled "An Act to provide for the operation of 10 transportation systems while under Federal control, for 11 the Just compensation of their owners and for other 12 purposes," flve-slxths of the tax Imposed by paragrapn 13 (1) of subdivision (a) and four-fifths of the tax 14 imposed by paragraph (2) of subdivision (a) shall be 15 treated as levied by an Act In amendment of Title I 16 of the Revenue Act of 1917. 17 18 Conditional and Other Exemptions. 19 20 SECTION 231. That the following organizations 21 shall be exempt from taxation under this title — 22 (1) Labor, agricultural, or horticultural organlza- 23 tions; 24 (2) Mutual savings banks not having a capital stock 25 represented by shares; 26 (3) Fraternal beneficiary societies, orders, or asso- 27 ciatlons, (a) operating under the lodge system or for 28 the exclusive benefit of the members of a fraternity 29 Itself operating under the lodge system, and (b) pro- 30 viding for the payment of life, sick, accident, or other 31 benefits to the members of such society, order, or asso- 32 elation or their dependents; 33 (4) Domestic building and loan associations and co- 34 operative banks without capital stock organized and 35 operated for mutual purposes and without profit; 36 (5) Cemetery companies owned and operated exclu- 37 sively for the benefit of their members; 38 (6) Corporations organized and operated exclusively 39 for religious, charitable, scientific, or educational pur- 40 poses, or for the prevention of cruelty to children or 41 animals, no part of the net earnings of which Inures to 42 the benefit of any private stockholder or individual; 43 (7) Business leagues, chambers of commerce, or 44 boards of trade, not organized for profit and no part 45 of the net earnings of which inures to the benefit of 4&any private stockholder or individual; 47 (8) Civic leagues or organizations not organized for 48 profit but operated exclusively for the promotion of 49 social welfare; 50 (9) Clubs organized and operated exclusively for 51 pleasure, recreation, and other nonprofitable purposes, 52 no part of the net earnings of which Inures to the 53 benefit of any private stockholder or member; 54 (10) Farmers' or other mutual hall, cyclone, or fire 55 Insurance companies, mutual ditch or irrigation com- 56 panics, mutual or cooperative telephone companies, or 57 like organizations of a purely local character, the In- 68 come of which consists solely of assessments, dues. 74 and fees collected from members for the sole purpose % of meeting expenses; 8 (11) Farmers', fruit growers', or like associations, 3 Fruit Growers organized and operated as sales agents for the purpose 4 of marketing the products of members and turning 5 back to them the proceeds of sales, less the necessary 6 selling expenses, on the basis of the quantity of produce 7 furnished by them; 8 (12) Corporations organized for the exclusive pur- 9 Special pose of holding title to property, collecting income 10 therefrom, and turning over the entire amount thereof, 11 less expenses, to an organization which itself is ex- 12 empt from the tax imposed by this title; 13 (13) Federal land banks and national farm-loan as- 14 Federal Land sociations as provided in section 26 of the Act ap- 15 Banks — proved July 17, 1916, entitled "An Act to provide cap- 16 Farm Loan ital for agricultural development, to create standard 17 Associations forms of investment based upon farm mortgage, to 18 equalize rates of interest upon farm loans, to furnish 19 a market for United States bonds, to create Govern- 20 ment depositaries and financial agents for the United 21 States, and for other purposes"; 22 (14) Personal service corporations. 28 24 Net Income Defined. 25 26 SECTION 232. That in the case of a corporation 27 Net Income subject to the tax imposed by section 230 the term 28 Defined "net income" means the gross income as defined in 29 section 233 less the deductions allowed by section 234, 30 and the net income shall be computed on the same 31 basis as is provided in subdivision (b) of section 212 32 or in section 226. 33 34 Gross Income Defined. 35 36 SECTION 233. (a) That in the case of a corporation 37 Gross Income subject to the tax imposed by section 230 the term 38 "gross income" means the gross Income as defined 39 in section 213, except that: 40 (1) In the case of life Insurance companies there 41 Life Ins. Go's shall not be included in gross income such portion 42 of any actual premium received from any individual 43 policyholder as is paid back or credited to or treated as 44 an abatement of premium of such policyholder within 45 the taxable year. 46 (2) Mutual marine Insurance companies shall Include 47 Mutual Marine in gross Income the gross premiums collected and re- 48 Ins. Go's ceived by them less amounts paid for reinsurance. 49 (b) In the case of a foreign corporation gross Income 50 Foreign Corp. includes only the gross income from sources within 51 the United States, including the Interest on bonds, 52 notes, or other Interest-bearing obligations of resi- 53 dents, corporate or otherwise, dividends from resident 54 corporations, and including all amounts received (al 55 though paid under a contract for the sale of goods 56 or otherwise) representing profits on the manufacture 57 and disposition of goods within the United States. 68 75 Ddduotlons Expenses Dednotiong Allowed. Interest Taxes Losses Bad Debts Dividends 3 SECTION 234. (a) That in computing the net in- 4 come of a corporation subject to the tax imposed by 6 section 230 there shall be allowed as deductions: 6 (1) All the ordinary and necessary expenses paid 7 or Incurred during the taxable year in carrying on any 8 trade or business, including a reasonable allowance for 8 salaries or other compensation for personal services 10 actually rendered, and including rentals or other pay- 11 ments required to be made as a condition to the con- IS tinned use or possession of property to which the cor- 13 poration has not taken or is not taking title, or In which 14 it has no equity; 15 (2) All interest paid or accrued within the taxable 16 year on its indebtedness, except on indebtedness In- 17 curred or continued to purchase or carry obligations 18 or securities (other than obligations of the United 19 States Issued after September 24, 1917) the interest 80 upon which is wholly exempt from taxation under this ai title as Income to the taxpayer, or, in the case of a 22 foreign corporation, the proportion of sUch interest 83 which the amount of its gross income from sources* 24 within the United States bears to the amount of Its 26 gross income from all sources within and without the 26 United States; 27 (3) Taxes paid or accrued within the taxable year 28 imposed (a) by the authority of the United States, 29 except income, war profits and excess-profits taxes; or 30 (b) by the authority of any -of its possessions, except 31 the amount of income, war profits and excess-profits 32 taxes allowed as a credit under section 238; or (c) by 33 the authority of any State or Territory, or any county, 34 school district, municipality, or other taxing subdi- 35 vision of any State or Territory, not Including those 36 assessed against local benefits of a kind tending to 37 increase the value of the property assessed; or (d) in 38 the case of a domestic corporation, by the authority 89 of any foreign country, except the amount of Income, 40 war-profits and excess-profits taxes allowed as a credit 41 under section 238; or (e) in the case of a foreign cor- 42 poration, by the authority of any foreign country 43 (except income, war-profits and excess-profits taxes, 44 and taxes assessed against local benefits of a kind 45 tending to increase the value of the property assessed), 46 upon the property or business: Provided, That In the 47 case of obligors specified In subdivision (b) of section 48 221 no deduction for the payment of the tax imposed by 49 this title or any other tax paid pursuant to the con- 60 tract or provision referred to In that subdivision, shall 51 be allowed; 52 (4) Losses sustained during the taxable year and 53 not compensated for by Insurance or otherwise; 54 (5) Debts ascertained to be worthless and charged 55 off within the taxable year; 56 (6) Amounts deceived as dividends from a corpora- 57 tion which Is taxable under this title upon Its net 58 Income, and amounts received as dividends from a per- 76 sonal service corporation out of earnings or profits upon which income tax has been imp'osed by Act of Congress; (7) A reasonable allowance for the exhaustion, wear and tear of property used in the trade or business, in- cluding a reasonable allowance for obsolescence; (8) In the case of buildings, machinery, equip- ment, or other facilities, constructed, erected, installed, or acquired, on or after April 6, 1917, for the produc- tion of articles contributing to the prosecution of the present war, and in the case of vessels constructed or acquired on or after such date for the transportation of articles or men contributing to the prosecution of the present war, there shall be allowed a reasonable deduction for the amortization of such part of the cost of such facilities or vessels as has been borne by the taxpayer, but not again including any amount otherwise allowed under this title or previous acts of Congress as a deduction in computing net Income. At any time within three years after the termination of the present war the Commissioner may, and at the request of the taxpayer shall, re-examine the return, and if he then finds as a result of an appraisal or from other evidence that the deduction originally al- lowed was Incorrect, the taxes imposed by this title and by Title III for the year or years affected shall be redetermined; and the amount of tax due upon such redetermination, If any, shall be paid upon notice and demand by the collector, or the amount of tax over- paid, if any, shall be credited or refunded to the tax- payer in accordance with the provisions of section 252; (9) In the case of mines, oil and gas wells, other natural deposits, and timber, a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar conditions in each case, based upon cost including cost of development not otherwise deducted: Provided, That In the case of such prop- erties acquired prior to March 1, 1913, the fair market value of the property (or the taxpayer's interest there- in) on that date shall be taken in lieu of cost up to that date: Provided further, That in the case of mines, oil and gas wells, discovered by the taxpayer, on or after March 1, 1913, and not acquired as the re- sult of purchase of a proven tract or lease, where the fair market value of the property Is materially dis- proportionate to the cost, the depletion allowance shall be based upon the fair market value of the property at the date of the discovery, or within 30 days there- after; such reasonable allowance In all the above cases to be m.ade under rules and regulations to be pre- scribed by the Commissioner with the approval of the Secretary. In the case of leases the deductions allowed by this paragraph shall be equitably apportioned be- tween the lessor and lessee; (10) In the case of insurance companies, in addi- tion to the above: (a) The net addition required by law to be made within the taxable year to reserve funds (including in the case of assessment Insurance companies the actual deposit of sums with State or 1 2 3 Depreciation 4 5 6 Special War 7 Loss and 8 Depreciation 9 10 11 12 13 14 15 16 17 18 1.9 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 43 49 50 51 52 53 54 Insurance Co's 55 56 57 58 77 Life, Health, Accident Mutual Marine Ins. Co. Mutual Ins. Other Than Life or Mutual Marine Deductions for Special Losses 1 Territorial officers pursuant to law as additions to 2 guarantee or reserve funds) ; and (b) the sums other 3 than dividends paid within the taxable year on policy 4 and annuity contracts; B (11) In the case of corporations Issuing policies cov- 6 ering life, health and accident insurance combined in 7 one policy issued on the weekly premium payment plan 8 continuing for life and not subject to cancellation, in 9 addition to the above, such portion of the net addition 10 (not required by law) made within the taxable year to 11 reserve funds as the Commissioner finds to be required 19 for the protection of the holders of such policies only; 13 (12) In the case of mutual marine insurance com- 14 panics, there shall be allowed, in addition to the deduc- 15 tlons allowed In paragraphs (1) to (10), Inclusive, 16 amounts repaid to policyholders on account of premiums 17 previously paid by them, and interest paid upon such 18 amounts between the ascertainment and the payment 19 thereof; 20 (13) In the case of mutual insurance companies 21 (other than mutual life or mutual marine Insurance 22 companies) requiring their members to make premium 23 deposits to provide for losses and expenses, there shall 24 be allowed, in addition to the deductions allowed In 25 paragraphs (1) to (10), inclusive (unless otherwise al- 86 lowed under such paragraphs), the amount of premium 27 deposits returned to their policyholders and the amount 98 of premium deposits retained for the payment of losses, 29 expenses, and reinsurance reserves; 30 (14) (a) At the time of filing return for the taxable 31 year 1918 a taxpayer may file a claim in abatement 32 based on the fact that he has sustained a substantial 33 loss (whether or not actually realized by sale or other 34 disposition) resulting from any material reduction (not 35 due to temporary fluctuation) of the value of the in- 36 ventory for such taxable year, or from the actual pay- 37 ment after the close of such taxable year of rebates 38 in pursuance of contracts entered Into during such 89 year upon sales made during such year. In such case ^ payment of the amount of the tax covered by such 41 claim shall not be required until the claim Is decided, 42 but the taxpayer shall accompany his claim with a bond 43 in double the amount of the tax covered by the claim, 44 with sureties satisfactory to the Commissioner, con- 45 ditloned for the payment of any part of such tax found 46 to be due, with Interest. If any part of such claim is 47 disallowed then the remainder of the tax due shall on 48 notice and demand by the Collector be paid by the tax- 49 payer with interest at the rate of 1 per centum per 50 month from the time the tax would have been due had 81 no such claim been filed. If it is shown to the satls- 88 faction of the Commissioner that such substantial loss 83 has been sustained, then in computing the taxes Im- 64 posed by this title and by Title III the amount of such 55 loss shall be deducted from thtf net Income, (b) If no 56 such claim is filed, but it Is shown to the satisfaction 57 of the Commissioner that during the taxable year 1919 58 the taxpayer has sustained a substantial loss of the 78 character above described then the amount of such 1 loss shall be deducted from the net income for the tax- 2 .Die year 1918 and the taxes imposed by this title and 3 by Title III for such year shall be redet-ermined accord- 4 Ingly. Any amount found to be due to the taxpayer 6 upon the basis of such redetermination shall be cred- 6 Ited or refunded to the taxpayer in accordance with the 7 provisions of section 252. 8 (b) In the case of a foreign corporation the deduc- 9 Foreign tion allowed in subdivision (a), except those allowed 10 Corporation in paragraph (2) and in clauses (a), (b), and (c) of H Deductions paragraph (3), shall be allowed only if and to the ex- 12 tent that they are connected with income arising from 13 a source within the United States; and the proper ap- 14 portionment and allocation of the deductions with re- 15 spect to sources of income within and without the 16 United States shall be determined under rules and regu- 1^ latlons prescribed by the Commissioner with the ap- 1« proval of the Secretary. 19 20 Items Hot Deductible 21 Items Not 22 Deductible SECTION 235. That in computing net income no 23 deduction shall in any case be allowed In respect of 24 any of the Items specified in section 215. 25 26 Credits Allowed. 27 Credits 28 Allowed SECTION 236. That for the purpose only of the 29 tax Imposed by section 230 there shall be allowed the 30 following credits: 31 (a) The amount received as Interest upon obligations 32 Interest of the United States and bonds Issued by the War 33 Finance Corporation, which Is included In gross Income 34 under section 233; 35 (b) The amount of any taxes imposed by Title III 36 Taxes for the same taxable year: Provided, That In the case 37 of a corporation which makes return for a fiscal year 38 beginning in 1917 and ending in 1918, in computing the 39 tax as provided In subdivision (a) of section 205, the 40 tax computed for the entire period under Title II of 41 the Revenue Act of 1917 shall be credited against the 42 net Income computed for the entire period under Title I 43 of the Revenue Act of 1916 as amended by the Revenue 44 Act of 1917 and under Title I of the Revenue Act of 45 1917, and the tax computed for the entire period under 46 Title III of this Act at the rates prescribed for the 47 calendar year 1918 shall be credited against the net 43 Income computed for the entire period under this title; ^^ and FO (c) In the case of a domestic corporation, $2,000. 51 Exemption Payment of Tax At Source. 53 54 SECTION 237. That In the case of foreign corpo- 55 Foreigfn Corp. rations subject to taxation under this title not en- 56 Tax on gaered In trade or business within the United States 57 Income to Be pnd not having any office or place of business therein, 58 Withheld 79 and Paid at Source Credit for Income, War-Proflts and Excess- Profits Taxes Satisfactory Evidence Required 1 2 3 4 6 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 34 38 36 37 38 39 40 41 42 43 44 48 3\ln VMiere Fiscal 47 Year is Other 48 Tlian 49 Calendar Year 50 there shall be deducted and withheld at the source the same manner and upon the same items of inconwf as is provided in section 221 a tax equal to 10 per centum thereof, and such tax shall be returned and paid in the same manner and subject to the same con- ditions as provided in that section: Provided, That in the case of interest described in subdivision (b) of that section the deduction and withholding shall he at the rate of 2 per centum. Credit for Taxes. SECTION 238. (a) That in the case of a domestic corporation the total taxes imposed for the taxable year by this title and by Title III shall be credited with the amount of any income, war-proflts and excess- profits taxes paid during the taxable year to any for- eign country, upon income derived from sources there- in, or to any possession of the United States. If accrued taxes when paid differ from the amounts claimed as credits by the corporation, or if any tax paid is refunded in whole or in part, the corporation shall at once notify the Commissioner who shall re- determine the amount of the taxes due under this title and under Title III for the year or years affected, and the amount of taxes due upon such redetermination, if any, shall be paid by the corporation upon notice and demand by the Collector, or the amount of taxes over- paid, if any, shall be credited or refunded to the cor- poration in accordance with the provisions of section 252. In the case of such a tax accrued but not paid, the Commissioner as a condition precedent to the al- lowance of this credit may require the corporation to give a bond with sureties satisfactory to and to be approved by him in such penal sum as he may require, conditioned for the payment by the taxpayer of any amount of taxes found due upon any such redetermina- tlon: and the bond herein prescribed shall contain such further conditions as the Commissioner may require. (b) This credit shall be allowed only if the taxpayer furnishes evidence satisfactory to the Commissioner showing the amount of Income derived from sources within such foreign country or such possession of the United States, as the case may be, and all other in- formation necessary for the computation of such credit. (c) If a domestic corporation makes a return for a fiscal year beginning In 1917 and ending in 1918, only that proportion of this credit shall be allowed which the part of such pei'iod within the calendar year 191S bears to the entire period. 63 Oorporatlon Returns. 54 Returns 65 SECTION 239. That every corporation subject to 60 taxation under this title and * every personal service 67 corporation shall make a return, stating specifically 68 the items of its gross income and the deductions and credits allowed by this title. The return shall be 1 ^ sworn to by the president, vice-president, or other 2 ^ principal officer and by the treasurer or assistant 3 treasurer. If any foreign corporation has no office or 4 place of business in the United States but has an 5 agent in the United States, the return shall be made 6 by the agent. In cases where receivers, trustees in 7 bankruptcy, or assignees are operating the property or 8 business of corporations, such receivers, trustees, or 9 assignees shall make returns for such corporations 10 in the same manner and form as corporations are re- 11 quired to make returns. Any tax due on the basis of 12 such returns made by receivers, trustees, or assignees 13 shall be collected in the same manner as if collected 14 from the corporations of whose business or property 15 they have custody and control. 16 Returns made under this section shall be subject 17 to the provisions of sections 226 and 228. 18 When return is made under section 226 the credit 19 provided in subdivision (c) of section 236 shall be 20 reduced to an amount which bears the same ratio to 21 the full credit therein provided as the number of 22 months in the period for which such return is made 23 bears to twelve months. 24 25 Consolidated Betnms. 26 27 SECTION 240. (a) That corporations which are af- 28 Consolidated filiated within the meaning of this section shall, under 29 Returns of regulations to be prescribed by the Commissioner with 30 Income and the approval of the Secretary, make a consolidated re- 31 Invested turn of net Income and Invested capital for the pur- 32 Capital, poses of this title and Title III, and the taxes there- 33 under shall be computed and determined upon the 34 basis of such return: Provided, That there shall be 35 taken out of such consolidated net Income and Invested 36 capital, the net Income and Invested capital of any 37 such affiliated corporation organized after August 1, 38 1914, and not successor to a then existing business, 50 39 per centum or more of whose gross Income consists of 40 gains, profits, commissions, or other income, derived 41 from a government contract or contracts made between 42 April 6, 1917, and November 11, 1918, both dates inclu- 43 sive. In such case the corporation so taken out shall 44 be separately assessed on the basis of Its own invested 45 capital and net income and the remainder of such af-46 filiated group shall be assessed on the basis of the re- 47 maining consolidated invested capital and net income. 43 In any case In which a tax is assessed upon the 49 basis of a consolidated return, the total tax shall be SO computed In the first Instance as a unit and shall then 51 be assessed upon the respective affiliated corporations 52 in such proportions as may be agreed upon among 53 them, or, in the absence of any such agreement, then 54 on the basis of the net Income properly assignable to 55 each. There shall be allowed In computing the Income 56 tax only one specific credit of $2,000 (as provided in 57 section 236); in computing the war-profits credit (as 58 81 Affiliated Corporations Domestic Corporation Owning Majority stock of Foreign Corporation 1 a 3 4 6 6 7 8 9 10 11 12 13 14 16 16 17 18 19 20 21 24 26 27 28 29 80 31 82 Time and 33 Place for 34 Filing 35 Returns 36 87 40 41 48 provided in section 311) only one specific exemption $3,000; and in computing the excess-profits credit (a provided in section 312) only one specific exemption of $3,000. (b) For the purpose of this section two or more do- mestic corporations shall be deemed to be affiliated (1) if one corporation owns directly or controls through closely affiliated interests or by a nominee or nominees substantially all the stock of the other or others, or (2) if substantially all the stock of two or more corpora- tions is owned or controlled by the same interests. (c) For the purposes of section 238 a domestic cor- poration which owns a majority of the voting stock of a foreign corporation shall be deemed to have paid the same proportion of any income, war-profits and excess- profits taxes paid (but not including taxes accrued) by such foreign corporation during the taxable year to any foreign country or to any possession of the United States upon income derived from sources without the United States, which the amount of any dividends (not deductible under section 234) received by such domes- tic corporation from such foreign corporation during the taxable year bears to the total taxable income of such foreign corporation upon or with respect to whicii such taxes were paid: Provided, That in no such case shall the amount of the credit for such taxes exceed the amount of such dividends (not deductible under sec- tion 234) received by such domestic corporation during the taxable year. Time and Place for Filing Retoms. SECTION 241. (a) That returns of corporations ;^hall be made at the same time as is provided in sun- division (a) of section 227. (b) Returns shall be made to the collector of the listrict in which is located the principal place of business or principal office or agency of the corpora- tion, or, if it has no principal place of business or itrincipal office or agency in the United States, then to the collector at Baltimore, Maryland. Payment of Taxes to be Paid In Four Installments Extension of Time for Filinir Returns 44 PAST ZV — ADMINZSTBATIVi: PROVISIONS. 48 46 Payment of Taxes. 47 48 SECTION 250. (a) That except as otherwise pro- 49 vlded in this section and sections 221 and 237 the tax 50 shall be paid In four installments, each consisting of 61 one-fourth of the total amount of the tax. The first 68 Installment shall be paid at the time fixed by law for 63 filing the return, and the second installment shall be 64 paid on the fifteenth day of the third month, the third 65 Installment on the fifteenth day of the sixth month, 66 and the fourth Installment on the fifteenth day of the 57 ninth month, after the time fixed by law for filing 58 the return. Where an extension of time for filing a return is granted the time for payment of the first in- 1 stallment shall be postponed until the date of the ex- 2 piration of the period of the extension, but the time 3 for payment of the other installments shall not be post- 4 poned unless the Commissioner so provides in granting 5 the extension. In any case in which the time for the 6 payment of any installment is at the request of the tax- 7 payer thus postponed, there shall be added as part 8 of such installment interest thereon at the rate of i^ of 9 1 per centum per month from the time it would have 10 been due if no extension had been granted, until paid. 11 If any installment is not paid when due, the whole 12 amount of the tax unpaid shall become due and pay- 13 able upon notice and demand by the collector. 14 The tax may at the option of the taxpayer be paid 15 in a single payment instead of in installments, in 16 which case the total amount shall be paid on or before 17 the time fixed by law for filing the return, or, where an 18 extension of time for filing the return has been granted, 19 on or before the expiration of the period of such ex- 20 tension. 21 (b) As soon as practicable after the return is filed, 22 the Commissioner shall examine it. If it then appears 23 that the correct amount of the tax is greater or less 23 than that shown in the return, the installments shall 26 be recomputed. If the amount already paid exceedsj26 that which should have been paid on the basis of the! 27 Tax May be Paid in Single Payment Excess Installment Payment installments as recomputed, the excess so paid shall When Installment Payment is Too Small be credited against the subsequent installments; and 29 If the amount already paid exceeds the correct amount 30 of the tax, the excess shall be credited or refunded tO|31 the taxpayer in accordance with the provisions of[32 section 252. If the amount already paid is less than that which should have been paid, the difference shall, to the extent rot covered by any credits then due to the 36 taxpayer under section 252, be paid upon notice and[37 demand by the collector. In such case if the return is made in good faith and the understatement of the amount in the return is not due to any fault of the taxpayer, there shall be no penalty because of such understatement. If the understatement is due to negli- gence on the part of the taxpayer, but without intent to defraud, there shall be added as part of the tax 5 per centum of the total amount of the deficiency, plusi45 interest at the rate of 1 per centum per month on. 46 the amount of the deficiency of each installment fi'om.47 the time the Installment was due. {48 If the understatement is false or fraudulent with 49 False or intent to evade the tax, then, in lieu of the penalty 50 Fraudulent provided by section 3176 of the Revised Statutes, as 51 Understate- Rmended, for false or fraudulent returns willfully 52 ment made, but in addition to other penalties provided by 53 law for false or fraudulent returns, there shall be 64 added as part of the tax 50 per centum of the amount 66 of the deficiency. 56 Payment on (c) If the return is made pursuant to section 3176 67 Notice and of the Kevised Statutes as amended, the amount of 68 Demand 28 83 1 tax determined to be due under such return shall be 2 paid upon notice and demand by the collector. Assessment May 3 (d) Except In the case of false or fraudulent re- Be Made 4 turns with Intent to evade the tax, the amount of Within Five 5 tax due under any return shall be determined and Years 6 assessed by the Commissioner within five years after 7 the return was due or was made, and no suit or pro- 8 ceeding for the collection of any tax shall be begun 9 after the expiration of five years after the date when 10 the return was due or was made. In the case of such H false or fraudulent returns, the amount of tax due 12 may be determined at any time after the return Is 13 filed, and the tax may be collected at any time after 14 it becomes due. Unpaid taxes 15 (e) If any tax remains unpaid after the date when 16 it Is due, and for ten days after notice and demand 17 by the collector, then, except In the case of estates 18 of Insane, deceased, or Insolvent persons, there shall 19 be added as part of the tax the sum of 5 per centum 20 on the amount due but unpaid, plus Interest at the 21 rate of 1 per centum per month upon such amount from 22 the time It became due: Provided, That as to any 23 such amount which Is the subject of a bona fide claim 24 for abatement such sum of 5 per centum shall not 25 be added and the Interest from the time the amount 26 was due until the claim Is decided shall be at the rate 27 of % of 1 per centum per month. 28 In the case of the first Installment provided for In 29 subdivision (a) the Instructions printed on the return 30 shall be deemed sufficient notice of the date when 31 the tax Is due and sufficient demand, and the tax- 32 payers' computation of the tax on the return shall 33 be deemed sufficient notice of the amount due. 34 (f) In any case In which In order to enforce pay- 35 ment of a tax It is necessary for a collector to cause 36 a warrant of distraint to be served, there shall also 87 be added as part of the tax the sum of $5. Evasion of tax 38 (g) If the Commissioner finds that a taxpayer de- 89 signs quickly to depart from the United States or to 40 remove his property therefrom, or to conceal himself 41 or his property therein, or to do any other act tending 42 to prejudice or to render wholly or partly Ineffectual 43 proceedings to collect the tax for the taxable year 44 then last past or the taxable year then current unless 45 such proceedings be brought without delay, the Com- 46 missioner shall declare the taxable period for such 47 taxpayer terminated at the end of the calendar month 48 then last past and shall cause notice of such finding 49 and declaration to be given the taxpayer, together 60 with a demand for Immediate payment of the tax for 51 the taxable period so declared terminated and of the 68 tax for the preceding taxable year or so much of said 53 tax as Is unpaid, whether or not the time otherwise 64 allowed by law for filing return and paying the tax 55 has expired: and such taxes shall thereupon become 56 immediately due and payable. Ifi any action or suit 57 brought to enforce payment of taxes made due and 68 payable by virtue of the provisions of this sub 84 division the finding of the Commissioner, made as 1 herein provided, whether made after notice to the tax- 2 payer or not, shall be for all purposes presumptive 3 evidence of the taxpayer's design. A taxpayer who 4 is not in default in making any return or paying in- 6 come, war profits, or excess-profits tax under any Act 6 of Congress may furnish to the United States, under 7 regulations to be prescribed by the Commissioner with 8 the approval of the Secretary, security approved by 9 the Commissioner that he will duly make the return 10 next thereafter required to be filed and pay the tax 11 next thereafter required to be paid. The Commissioner 12 may approve and accept in like manner security for 13 return and payment of taxes made due and payable 14 by virtue of the provisions of this subdivision, pro- 15 vided the taxpayer has paid in full all other income, 16 war profits, or excess-profits taxes due from him under 17 any Act of Congress. If security is approved and 18 accepted pursuant to the provisions of this subdivision 19 and such further or other security with respect to the 20 tax or taxes covered thereby is given as the Commis- 21 sioner shall from time to time find necessary and 22 require, payment of such taxes shall not be enforced 23 by any proceedings under the provisions of this sub- 24 division prior to the expiration of the time otherwise 25 allowed for paying such respective taxes. 26 27 Receipts for Taxes. 28 29 SECTION 251. That every collector to whom any 30 Receipts for payment of any tax is made under the provisions of 31 Taxes Given this title shall upon request give to the person mak- 32 Upon Ing such payment a full written or printed receipt, 33 Request stating the amount paid and the particular account for 34 which such payment was made; and whenever any 35 debtor pays taxes on account of payments made or to 36 be made by him to separate creditors the collector shall, 37 if requested by such debtor, give a separate receipt for 38 the tax paid on account of each creditor in such form 39 that the debtor can conveniently produce such receipts 40 separately to his several creditors in satisfaction of 41 their respective demands up to the amounts stated in 42 the receipts; and such receipt shall be sufficient evi- 43 dence in favor of such debtor to justify him in with- 44 holding from his next payment to his creditor the 45 amount therein stated; but the creditor may, upon 46 giving to his debtor a full written receipt acknowledg- 47 Ing the payment to him of any sum actually paid and 48 accepting the amount of tax paid as aforesaid (specify- 49 ing the same) as a further satisfaction of the debt to 50 that amount, require the surrender to him of such col- 51 lector's receipt. 52 Refunds. 63 64 SECTION 252. That if, upon examination of any re- 55 Refund of Tax turn of Income made pursuant to this Act, the Act of 56 August 5, 1909, entitled "An Act to provide revenue, 57 equalize duties, and encourage the industries of the 58 85 Penalties 1 a s 4 6 6 7 8 9 10 11 12 13 14 16 16 17 18 19 ao 21 22 23 24 26 26 27 28 29 30 31 37 United States, and for other purposes," the Act of Oc- tober 3, 1913, entitled "An Act to reduce tariff duties and to provide revenue for the Government, and for other purposes," the Revenue Act of 1916, as amended, or the Revenue Act of 1917, it appears that an amount of income, war profits or excess-profits tax has been paid in excess of that properly due, then, notwithstand- ing the provisions of section 3228 of the Revised Stat- utes, the amount of the excess shall be credited against any income, war profits or excess-profits taxes, or in- stallment thereof, then due from the taxpayer under any other return, and any balance of such excess shall be immediately refunded to the taxpayer: Provided, That no such credit or refund shall be allowed or made after five years from the date when the return was due, unless before the expiration of such five years a claim therefor is filed by the taxpayer. Penalties. SECTION 253. That any Individual, corporation, or partnership required under this title to pay or collect any tax, to make a return or to supply information, who fails to pay or collect such tax, to make such re- turn, or to supply such information at the time or times required under this title, shall be liable to a penalty of not more than $1,000. Any individual, cor- poration, or partnership, or any officer or employee of any corporation or member or employee of a partner- ship, who willfully refuses to pay or collect such tax, to make such return, or to supply such information at the time or times required under this title, or who will- fully attempts in any manner to defeat or evade the tax imposed by this title, shall be guilty of a mis- demeanor and shall be fined not more than $10,000 or imprisoned for not more than one year, or both, to- gether with the costs of prosecution. 39 Returns of Payments of Dividends. 40 Return of 41 SECTION 254. That every corporation subject to the Payments of 42 tax imposed by this title and every personal service Dividends 43 corporation shall, when required by the Commissioner, 44 render a correct return duly verified under oath, of its 45 payments of dividends, stating the name and address 46 of each stockholder, the number of shares owned by 47 him, and the amount of dividends paid to him. 48 ^^ Betnms of Broilers. 50 Brokern— bi SECTION 255. That every individual, corporation, or Returns of 52 partnership doing business as a broker shall, when re- 63 quired by the Commissioner, render a correct return 64 duly verified under oath, under such rules and regula- 65 tlons as the Commissioner, with the approval of the 66 Secretary, may prescribe, showing the names of cus- 67 tomers for whom such Individual, corporation, or part- 68 nership has transacted any business, with such details 86 as to the profits, losses or other information which the Commissioner may require, as to each of such cus- tomers, as will enable the Commissioner to determine whether all income tax due on profits. X)r gains ot such customers has been paid. Information at Source. 1 2 3 4 6 6 7 8 SECTION 256, That all individuals, corporations, 9 and partnerships, in whatever capacity acting, includ- 10 ing lessees or mortgagors of real or personal property, 11 fiduciaries, and employers, making payment to another 12 individual, corporation, or partnership, of interest, rent, 13 salaries, wages, premiums, annuities, compensations, re- 14 munerations, emoluments, or other fixed, or determin- 15 able gains, profits, and income (other than payments 16 described in sections 254 and 255), of $1,000 or more in 17 any taxable year, or, in the case of such payments made 18 by the United States, the officers or employees of the 19 United States having information as to such payments 20 and required to make returns in regard thereto by the 21 regulations hereinafter provided for, shall render a true 22 and accurate return to the Commissioner, under such 23 regulations and in such form and manner and to such 24 extent as may be prescribed by him with the approval 25 of the Secretary, setting forth the amount of such 26 gains, profits, and income, and the name and address 27 of the recipient of such payment. 23 Such returns may be required, regardless of amounts, 29 (1) in the case of payments of interest upon bonds, 30 mortgages, deeds of trust, or other similar obligations 31 of corporations, and (2) in the case of collections of 32 items (not payable in the United States) of interest 33 upon the bonds of foreign countries and interest upon 34 the bonds of and dividends from foreign corporations 35 by individuals, corporations, or partnerships, undertak- 36 Ing as a matter of business or for profit the collection 37 of foreign payments of such interest or dividends by 38 means of coupons, checks, or bills of exchange. 39 When necessary to make effective the provisions of 40 this section the naine and address of the recipient of 41 income shall be furnished upon demand of the Individ 42 ual, corporation, or partnership paying the income. 43 The provisions of this section shall apply to the cal- 44 endar year 1918 and each calendar year thereafter, but 45 shall not apply to the payment of interest on obliga- 46 tions of the United States. 47 48 Returns to be Fulilic Records. 49 50 SECTION 257. That returns upon which the tax has 51 been determined by the Commissioner shall constitute 52 public records; but they shall be open to inspection only 53 upon order of the President and under rules and regu- 54 lations prescribed by the Secretary and approved by 55 the President: Provided, That the proper officers of 56 any State Imposing an income tax may, upon the re- 57 quest of the governor thereof, have access to the re- 58 Information Source Return of Required at Payments of Interest on Bonds, Mortgages Etc. Returns to be Public Records 87 1 turns of any corporation, or to an abstract thereof 2 showing the name and income of the corporation, at 3 such times and in such manner as the Secretary may Examination of 4 prescribe: Provided further, That all bona fide stock- Returns by B holders of record owning 1 per centum or more of the Stockholders 6 outstanding stock of any corporation shall, upon mak- 7 ing request of the Commissioner, be allowed to examine 8 the annual income returns of such corporation and of 9 its subsidiaries. Any stockholder who pursuant to the 10 provisions of this section is allowed to examine the re- 11 turn of any corporation, and who makes known in any 12 manner whatever not provided by law the amount or 13 source of income, profits, losses, expenditures, or any 14 particular thereof, set forth or disclosed in any such 15 return, shall be guilty of a misdemeanor and be pun- 16 ished by a fine not exceeding $1,000, or by imprison- 17 ment not exceeding one year, or both. List of Persons 18 The Commissioner shall as soon as practicable in Making 19 each year cause to be prepared and made available to Returns 80 public inspection in such manner as he may determine, 81 in the office of the collector in each internal-revenue 88 district and in such other places as he may determine, 88 lists containing the names and the post-office addresses 84 of all individuals making income-tax returns in such 86 district. 86 Publication of Statistics. 27 Publication of 88 SECTION 258. That the Commissioner, with the ap- Statistics 89 proval of the Secretary, shall prepare and publish an- 80 nually statistics reasonably available with respect to 31 the operation of the income, war profits and excess- 88 profits tax laws, including classifications of taxpayers 83 and of income, the amounts allowed as deductions, ex- •4 emptions, and credits, and any other facts deemed per- 86 tlnent and valuable. 86 97 Collection of Poreign Items. 88 Collection of 39 SECTION 259. That all individuals, corporations, or Foreign 40 partnerships undertaking as a matter of business or Items 41 for profit the collection of foreign payments of Interest 4ii or dividends by means of coupons, checks or bills of 48 exchange shall obtain a license from the Commissioner 44 and shall be subject to such regulations enabling the *S Government to obtain the information required under 48 this title as the Commissioner, with the approval of the 47 Secretary, shall prescribe; and whoever knowingly un- 48 dertakes to collect such payments without having ob- 48 tained a license therefor, or without complying with M such regulations, shall be guilty of a misdemeanor and 81 shall be fined not more than $5,000, or imprisoned for 88 not more than one year, or both. 68 64 Citizens of United States Possessions. 60 Citizens of U. S. 56 SECTION 260. That any individual who is a citizen Possessions 57 of any possession of the United States (but not other- 58 wise a citizen of the United States) and who Is not 88 a resident of the United States, shall be subject to 1 taxation under this title only as to income derived from 2 sources with the United States, and,, in such case the 3 tax shall be computed and paid in the same manner 4 and subject to the same conditions as In the case of 5 other persons who are taxable only as to income derived 6 from such sources. 7 8 Porto Rico and Philippine Islands. 9 10 SECTION 261. That in Porto Rico and the Philip- 11 Porto Rico, pine Islands the income tax shall be levied, assessed, 12 Philippine collected, and paid in accordance with the provisions of 13 Islands the Revenue Act of 1916 as amended. 14 Returns shall be made and taxes shall be paid under 15 . Title I of such Act in Porto Rico or the Philippine 16 Islands, as the case may be, by (1) every Individual 17 who is a citizen or resident of Porto Rico or the Philip- 18 pine Islands or derives Income from sources therein, 13 and ( 2 ) every corporation created or organized In Porto 20 Rico or the Philippine Islands or deriving income from 21 sources therein. An Individual who Is neither a citizen 22 nor a resident of Porto Rico or the Philippine Islands 23 but derives income from sources therein, shall be taxed 24 In Porto Rico or the Philippine Islands as a non-resi- 25 dent alien individual, and a corporation created or or- 26 ganized outside Porto Rico or the Philippine Islands 27 and deriving income from sources therein shall be taxed 28 In Porto Rico or the Philippine Islands as a foreign 29 corporation. For the purposes of section 216 and of 30 paragraph (6) of subdivision (a) of section 234 a tax 31 Imposed in Porto Rico or the Philippine Islands upon 32 the net Income of a corporation shall not be deemed 33 to be a tax under this title. 34 The Porto Rican or Philippine Legislature shall have 85 power by due enactment to amend, alter, modify, or re- 36 peal the Income tax laws In force in Porto Rico or the 37 Philippine Islands, respectively. 38 89 40 TITLE III.— WAR-PROFITS AND EXCESS-PROFITS 41 War-Profits & TAX. 42 Bxcess- 43 Profits Tax PART Z.— aSNERAZ. DEPINXTZOITS. 44 45 SECTION 300. That when used in this title the 46 Definitions terms "taxable year," "fiscal year," "personal service 47 corporation," "paid or accrued," and "dividends" shall 48 have the same meaning as provided for the purposes 49 of Income tax in sections 200 and 201. The first tax- 50 able year for the purposes of this title shall be the 51 same as the first taxable year for the purposes of the 52 income tax under Title II. 53 54 PART ZZ.— -IMPOSITZOIT OP TAX. 55 Imposition of 56 Tax SECTION 301. (a) That In lieu of the tax Imposed 57 by Title II of the Revenue Act of 1917, but In addi- 58 1 tlon to the other taxes imposed by this Act, there shall 2 be levied, collected, and paid for the taxable year 1918 3 uDon the net income of everv corooration a tax equal 4 to the sum of the following: 6 First Bracket 6 Pirst Bracket. 7 8 30 per centum of the amount of the net income in 9 excess of the excess-profits credit (determined under 10 section 312) and not in excess of 20 per centum of the 11 invested capital; Second Bracket 12 Second Bracket. 13 14 65 per centum of the amount of the net income in 15 excess of 20 per centum of the invested capital; 16 Third Bracket 17 Third Bracket. 18 19 The sum, if any, by which 80 per centum of the 20 amount of the net income in excess of the war-profits 21 credit (determined under section 311) exceeds the 22 amount of the tax computed under the first and second 23 brackets. 24 (b) For the taxable year 1919 and each taxable year 26 thereafter there shall be levied, collected, and paid upon 26 the net income of every corporation (except corpora- 27 tions taxable under subdivision (c) of this section) a 28 tax equal to the sum of the following: 29 First Bracket 30 Pirst Bracket. 31 32 20 per centum of the amount of the net income in 33 excess of the excess-profits credit (determined under 34 r-;ection 312) and not in excess of 20 per centum of the 35 invested capital'; Second Bracket 36 Second Bracket. 37 38 40 per centum of the amount of the net income in ex- 39 crss of 20 per centum of the invested capital. Year 1919 40 (c) For the taxable year 1919 and each taxable year 41 thereafter there shall be levied, collected, and paid upon 42 the net income of every corporation which derives in 43 such year a net income of more than $10,000 from any 44 fovernment contract or contracts made between April 45 6. 3917, and November 11, 1918, both dates inclusive, a 46 tax equal to the sum of the following: 47 (1) Such a portion of a tax computed at the rates 48 specified in subdivision (a) as the part of the net in- 49 come attributable to such government contract or con- 50 tracts bears to the entire net income. In computing 81 such tax the excess-profits credit and the war-profits 52 credit applicable to the taxable year shall be used; 88 (2) Such a portion of a tax computed at the rates 54 specified In subdivision (b) as the part of the net In- 55 come not attributable to such government contract or 66 contracts bears to the entire net income. 67 For the purpose of determining the part of the net 68 income attributable to such government contract or 90 contracts, the proper apportionment and allocation of 1 the deductions with respect to gross income derived 2 from such government contract or contracts and from 3 other sources, respectively, shall be determined under 4 rules and regulations prescribed by the Commissioner 5 with the approval of the Secretary. 6 (d) In any case where the full amount of the excess- 7 profits credit is not allowed under the first bracket of 8 subdivision (a) or (b), by reason of the fact that such 9 credit is in excess of 20 per centum of the invested 10 capital, the part not so allowed shall be deducted from 11 the amount in the second bracket. 12 (e) For the purposes of the Act approved March 21, 13 1918, entitled "An Act to provide for the operation of 14 transportation systems while under Federal control, for 15 the just compensation of their owners and for other 16 purposes," the tax imposed by this title shall be treated 17 as levied by an Act in amendment of Title II of the 18 Revenue Act of 1917. 19 SECTION 302. That the tax imposed by subdivision 20 Limitation of (a) of section 301 shall in no case be more than 30 per 21 Amount of centum of the amount of the net income in excess of 22 Tax $3,000 and not in excess of $20,000, plus 80 per centum 23 of the amount of the net income in excess of $20,000; 24 the tax imposed by subdivision (b) of section 301 25 shall in no case be more than 20 per centum of the 26 amount of the net income in excess of $3,000 and not 27 in excess of $20,000, plus 40 per centum of the amount 28 of the net income in excess of $20,000; and the above 29 limitations shall apply to the taxes computed under 30 subdivisions (a) and (b) of section 301, respectively, 31 when used in subdivision (c) of that section. Nothing 32 in this section shall be construed in such manner as to 33 increase the tax imposed by section 301. 34 SECTION 303. That if part of the net income of a 35 Separate corporation is derived (1) from a trade or business (or 36 Corporation a branch of a trade or business) in which the employ- 37 Where Part ment of capital Is necessary, and (2) a part (constltut- 38 of Business ing not less than 30 per centum of Its total net Income) 39 Requires No is derived from a separate trade or business (or a dis- 40 Capital tinctly separate branch of the trade or business) which 41 if constituting the sole trade or business would bring 42 it within the class of "personal service corporations," 43 then (under regulations prescribed by the Commissioner 44 with the approval of the Secretary) the tax upon the 45 first part of such net income shall be separately com- 46 puted (allowing in such computation only the same 47 proportionate part of the credits authorized In sec- 48 tions 311 and 312), and the tax upon the second part 49 shall be the same percentage thereof as the tax so com- 50 puted upon the first part is of such first part: Provided, 51 That the tax upon such second part shall In no case be 52 less than 20 per centum thereof, unless the tax upon the 53 entire net Income, if computed without benefit of this 54 section, would constitute less than 20 per centum of 55 such entire net income, in which event the tax shall be 56 determined upon the entire net income, without refer- 57 ence to this section, as other taxes are determined 58 91 Exempt Corporations Gold Mining Corporations Exempt to Certain Extent New Corporations Credits Allowed 1 under this title. The total tax computed under thla 2 section shall be subject to the limitations provided m 3 section 302. 4 SECTION 304. (a) That the corporations enumerat- 6 ed in section 231 shall, to the extent that they are ex- 6 empt from income tax under Title II, be exempt from 7 taxation under this title. 8 (b) Any corporation whose net income for the taxable 9 year is less than $3,000 shall be exempt from taxation 10 under this title. 11 (c) In the case of any corporation engaged In the 12 mining of gold, the portion of the net income derived 13 from the mining of gold shall be exempt from the tax 14 imposed by this title, and the tax on the remaining 15 portion of the net income shall be the proportion of a 16 tax computed without the benefit of this subdivision 17 which such remaining portion of the net income bears 18 to the entire net income. 19 SECTION 305. That if a tax is computed under this 20 title for a period of less than twelve months, the 21 specific exemption of $3,000, wherever referred to in 22 this title, shall be reduced to an amount which is the 23 same proportion of $3,000 as the number of months 24 in the period is of twelve months. 25 26 27 PART IZZ.— CREDITS. 28 29 SECTION 310. That as used in this title the term 30 "prewar period" means the calendar years 1911, 1912, 31 and 1913, or, if a corporation was not in existence dur- 32 ing the whole of such period, then as many of such 33 years during the whole of which the corporation was 34 in existence. 35 SECTION 311. (a) That the war-profits credit shall 36 consist of the sum of: 37 (1) A specific exemption of $3,000; and 38 (2) An amount equal to the average net Income of 89 the corporation for the prewar period, plus or minus, 40 as the case may be, 10 per centum of the difference be- 41 tween the average invested capital for the prewar 42 period and the Invested capital for the taxable year. If 43 the tax Is computed for a period of less than twelve 44 months such amount shall be reduced to the same 45 proportion thereof as the number of months In the 46 period is of twelve months. 47 (b) If the corporation had no net income for the pre- 48 war period, or if the amount computed under paragraph 49 (2) of subdivision (a) is less than 10 per centum of Its 50 Invested capital for the taxable year, then the war- 61 profits credit shall be the sum of: 62 (1) A specific exemption of $3,000; and 63 (2) An amount equal to 10 per centum of the In- 64 vested capital for the taxable year. 5S (c) If the corporation was not In existence during 66 the whole of at least one calendar year during the 87 prewar period, then, except as provided in subdivision 68 (d), the war-profits credit shall be the sum of: (1) A specific exemption of $3,000; and 1 (2) An amount equal to the same percentage of the 2 invested capital of the taxpayer for the taxable year 3 as the average percentage of net Income to invested 4 capital, for the prewar period, of corporations engaged 6 in a trade or business of the same general class aa 6 that conducted by the taxpayer; but such amount shall 7 in no case be less than 10 per centum of the invested 8 capital of the taxpayer for the taxable year. Such 9 average percentage shall be determined by the Com- LO missloner on the basis of data contained in return Ji 11 made under Title II of the Revenue Act of 1917, anvl 12 the average known as the median shall be used. If 13 such average percentage has not been determined and 14 published at least 30 days prior to the time when tb. 28 on the amount paid for such transportation withlrj 29 the United States of property transported from a poin^ 30 without the United States to a point within the United 31 States; 32 (b) A tax of 1 cent for each 20 cents or fraction 33 thereof of the amount paid to any person for the 34 transportation on or after such date, by rail or water 36 or by any form of mechanical motor power when in 36 competition with express by rail or water, of any 37 package, parcel, or shipment, by express, transported 38 from one point in the United States to another; and 39 a like tax on the amount paid for such transportation 40 within the United States of property transported from 41 a point without the United States to a point within the 42 United States; 43 (c) A tax equivalent to 8 per centum of the amount 44 paid for the transportation on or after such date of 45 persons by rail or water, or by any form of mechanical 46 motor power on a regular established line when in 47 competition with carriers by rail or water, from one 48 point in the United States to another or to any point 49 in Canada or Mexico, where the ticket or order therefor 50 is sold or issued in the United States, not including 51 the amount paid for commutation or season tickets for 52 trips less than thirty miles, or for transportation the 53 fare for which does not exceed 42 cents: Provided, 54 That where such water transportation lines are in 55 competition between American ports with foreign water 56 transportation lines from adjacent foreign ports, the tax 57 imposed under this subdivision on amounts paid for 58 107 staterooms Parlor Cars Etc. Oil Pipe Line Telegraph, Telephone, Cables Leased Wires Exemption Payer for Service Taxable Mileage Books, Tickets, etc. 1 water transportation between American ports shall not 2 exceed the amount of the transportation tax to which 3 such foreign water transportation lines are subjected by 4 their Government corresponding to this tax; B (d) A tax equivalent to 8 per centum of the amount 6 paid for seats, berths, and staterooms in parlor cars, 7 sleeping cars, or on vessels, used on or after such date 8 in connection with transportation upon which tax Is • imposed by subdivision (c) ; 10 (e) A tax equivalent to 8 per centum of the amount 11 paid for the transportation on or after such date of 12 oil by pipe line; 13 (f) In the case of each telegraph, telephone, cable, 14 or radio, dispatch, message, or conversation, which 16 originates on or after such date within the United 16 States, and for the transmission of which the charge 17 is more than 14 cents and not more than 50 cents, a 18 tax of 5 cents; and if the charge is more than 50 cents, 19 a tax of 10 cents: Provided, That only one payment 80 of such tax shall be required, notwithstanding the lines 21 or stations of one or more persons are used for the 02 transmission of such dispatch, message, or conversa- 23 tion; and 24 (g) A tax equivalent to 10 per centum of the amount 25 paid after such date to any telegraph or telephone 26 company for any leased wire or talking circuit special 27 service furnished after such date. This subdivision 28 shall not apply to the amount paid for so much of 29 such service as is utilized (1) in the collection and 80 dissemination of news through the public press, or 81 (2) in the conduct, by a common carrier or telegraph 82 or telephone company, of its business as such. 83 (h) No tax shall be imposed under this section upon 84 any payment received for services rendered to the 85 United States or to any State or Territory or the Dis- 88 trict of Columbia. The right to exemption under this 87 subdivision shall be evidenced In such manner as the 88 Commissioner, with the approval of the Secretary, may 89 by regulation prescribe. 40 41 SECTION 501. (a) That the taxes imposed by sec- 42 tion 500 shall be paid by the person paying for the 43 services or facilities rendered. 44 (b) If a mileage book used for transportation or 45 accommodation was purchased before November 1, 1917, 48 or if cash fare is paid, the tax imposed by section 417 500 shall be collected from the person presenting the 48 mileage book, or paying the cash fare, by the con- 49 ductor or other agent, when presented for such trans- 50 portation or accommodation, and the amount so col- 51 lected shall be paid to the United States in such manner 88 and at such times as the Commissioner, with the 68 approval of the Secretary, may prescribe; If a ticket 64 (other than a mileage book) was bought and partially 66 used before November 1, 1917, It shall not be taxed, 66 but if bought but not so used before section 500 takes 57 effect. It shall not be valid for passage until the tax 68 has been paid and such payment evidenced on the 108 ticket in such manner as the Commissioner, with the 1 approval of the Secretary, may by regulation prescribe. 2 (c) The taxes Imposed by section 5Q0 shall apply 3 to all services or facilities specified in such section 4 when rendered for hire, whether or not the agency 6 rendering them is a common carrier. In case a carrier 6 (other than a pipe line) principally engaged in ren- 7 derlng transportation services or facilities for hire 8 does not, because of its ownership of the goods trans- 9 ported, or for any other reason, receive the amount 10 which as a carrier it would otherwise charge, such 11 carrier shall pay a tax equivalent to the tax which 12 would be imposed upon the transportation of such goods 13 if the carrier received payment for such transporta- 14 tion, such tax, if It can not be computed from actual 15 rates or tariffs of the carrier, to be computed on the 16 basis of the rates or tariffs of other carriers for like 17 services as determined by the Commissioner. In the 18 case of any carrier (other than a pipe line) the prin- 19 cipal business of which is to transport goods belonging 20 to it on its own account and which only Incidentally 21 renders services for hire, the tax shall apply to such 22 services or facilities only as are actually rendered by 23 it for hire. Nothing in this or the preceding section 24 shall be construed as imposing a tax (1) upon the 25 transportation of any commodity which is necessary 26 for the use of the carrier in the conduct of its business 27 as such and is intended to be so used or has been so 28 used; or (2) upon the transportation of company ma- 29 terial transported by one carrier, which constitutes a 30 part of a railroad system, for another carrier wtilch 31 is also a part of the same system. 33 (d) The tax imposed by subdivision (e) of section 33 Oil and Pipe 500 shall apply to all transportation of oil by pipe 34 Lines line. In case no charge for transportation is made, 35 by reason of ownership of the commodity transported, 36 or for any other reason, the person transportingr by 37 pipe line shall pay a tax equivalent to the tax which 38 would be imposed if such person received payment for 39 such transportation, and if the tax can not be com- 40 puted from actual bona fide rates or tariffs, it shall be 41 computed (1) on the basis of the rates or tariffs of 42 other pipe lines for like services, as determined by 43 the Commissioner, or (2) if no such rates or tariffs 44 exist, on the basis of a reasonable charge for such 45 transportation, as determined by the Commissioner. 46 47 SECTION 502. That each person receiving any pay- 48 Monthly ments referred to in section 500 shall collect the 49 Returns of amount of the tax, if any, imposed by such section 50 Tax from the person making such payments, and shall make 51 Collected monthly returns under oath, in duplicate, and pay the 52 taxes so collected and the taxes Imposed upon it under 53 subdivision (c) or (d) of section 501 to the collector 54 of the district In which the principal office or place of 55 business is located. , 56 No carrier collecting the taxes imposed by subdivi- 57 sion (a) or (b) of section 500 shall be required to list 58 109 1 the amount of such tax separately in any bill of lading, 2 freight or express receipt, or other similar document, 3 if the total amount of the transportation charge and 4 the tax is stated therein. 6 Any person making a refund of any payment upon 6 which tax is collected under this section may repay 7 therewith the amount of the tax collected on such 8 payment; and the amount so repaid may be credited 9 against amounts included in any subsequent monthly 10 return. 11 The returns required under this section shall contain 12 such information, and be made at such times and in 13 such manner, as the Commissioner, with the approval 14 of the Secretary, may by regulation prescribe. 15 The tax shall, without assessment by the Commis- 16 sioner or notice from the collector, be due and pay- 17 able to the collector at the time so fixed for filing 18 the return. If the tax is not paid when due, there 19 shall be added as part of the tax a penalty of 5 per 20 centum, together with interest at the rate of 1 per 21 centum for each full month, from the time when the 22 tax became due. Insurance 24 Insurance. 25 26 SECTION 503. That from and after April 1, 1919, 27 there shall be levied, assessed, collected, and paid, in 28 lieu of the taxes imposed by section 504 of the Revenue ^ 29 Act of 1917, the following taxes on the issuance of in- 30 surance policies, including, in the case of policies is- 31 sued outside the United States (except those taxable 32 under Subdivision 15 of Schedule A of Title XI), their 33 delivery within the United States by any agent or 34 broker, whether acting for the insurer or the insured; 36 such taxes to be paid by the insurer, or by such agent 30 or broker: Life Insurance 37 (a) Life insurance: A tax equivalent to 8 cents on Policies 38 each $100 or fractional part thereof of the amount for 39 which any life is insured under any policy of insurance, 40 or other Instrument, by whatever name the same is 41 called: Provided, That on all policies for life insurance 42 only by which a life is insured not in excess of $500, 43 issued on the industrial or weekly or monthly pay- 44 raent plan of insurance, the tax shall be 40 per centum 45 of the amount of the first weekly premium or 20 per 46 centum of the amount of the first monthly premium, as 47 the case may be: Provided further. That on policies 48 of group life insurance, covering groups of not less 49 than 25 lives In the employ of the same person, for the 60 benefit of persons other than the employer, the tax 61 shall be equivalent to 4 cents on each $100 of the 62 aggregate amount for which the group policy is issued 63 and of any net Increase in the amount of the insur- 64 ance under such policy: And provided further. That 65 on all policies covering life, health, and accident in- 66 surance combined in one policy by which a life is In- 67 sured not in excess of $500, Issued on the industrial, or 68 weekly or monthly payment plan of insurance, the 110 tax shall be 40 per centum of the amount of the first 1 weekly premium or 20 per centum of the amount of 2 the first monthly premium, as the cas^^ may be; 3 (b) Marine, inland, and fire insurance: A tax equiv- 4 Marine, Fire alent to 1 cent on each dollar or fractional part there- 5 Insurance of of the premium charged under each policy of in- 6 surance or other instrument by whatever name the 7 same is called whereby insurance is made or renewed 8 upon property of any description (including rents or 9 profits), whether against peril by sea or inland waters, 10 or by fire or lightning', or other peril; 11 (c) Casualty insurance: A tax equivalent to 1 cent 12 Casualty on each dollar or fractional part thereof of the premium 13 Insurance charged under each policy of insurance or obligation of 14 the nature of indemnity for loss, damage, or liability 15 (except bonds and policies taxable under subdivision 2 16 of schedule A of Title XI) issued or executed or re- 17 newed by any person transacting the business of em 18 ployer's liability, workmen's compensation, accident, 19 health, tornado, plate glass, steam boiler, elevator, 20 burglary, automatic sprinkler, automobile, or other 21 branch of insurance (except life insurance, and Insurt 22 ance described and taxed in the preceding subdivision): 23 Provided, That in case of policies of insurance issued on 24 the industrial or weekly or monthly payment plan 25 the tax shall be 40 per centum of the amount of the 26 first weekly premium or 20 per centum of the amount 27 of the first monthly premium, as the case may be; 28 (d) Policies issued by any corporation enumerated in 29 Exempt section 231 and policies of reinsurance, shall be exempt 30 Corporations from the taxes imposed by this section. 31 32 SECTION 504. That every person issuing policie.-i 33 Monthly of Insurance upon the issuance of which a tax is im^ 34 Returns and posed by section 503 shall make monthly returns under 35 Payment of oath, in duplicate, and pay such tax to the collector 36 Tax of the district in which the principal office or place of, 37 business of such person is located. Such returns shalj 38 contain such information and be made at such timeg 39 and in such manner as the Commissioner, with the 40 approval of the Secretary, may by regulation prescribe. 41 The tax shall, without assessment by the Commis- 42 sioner or notice from the collector, be due and payable 43 to the collector at the time so fixed for filing the return. 44 If the tax is not paid when due, there shall be added as 45 part of the tax a penalty of 5 per centum, together with 46 interest at the rate of 1 per centum for each full month, 47 from the time when the tax became due. 48 49 50 51 TITLE VI.— TAX ON BEVERAGES. 52 Tax on 53 Beverasres SECTION 600. (a) That there shall be levied and 54 Distilled collected on all distilled spirits now in bond or that 55 Spirits have been or that may be hereafter produced In or 56 Imported Into the United States, except such distilled 57 spirits as are subject to the tax provided In section 58 111 1 604, In lieu of the internal-revenue taxes now imposed fl thereon by law, a tax of $2.20 (or, If withdrawn for 8 beverage purposes or for use in the manufacture or 4 production of any article used or intended for use as 5 a beverage, a tax of $6.40) on each proof gallon, or 6 wine gallon when below proof, and a proportionate 7 tax at a like rate on all fractional parts of such proof • or wine gallon, to be paid by the distiller or importer • when withdrawn, and collected under the provisions 10 of existing law. 11 (b) That the tax imposed by subdivision (a) on 12 distilled spirits intended for beverage purposes shall 18 not be due or payable on such spirits while stored in 14 any distillery, bonded warehouse, or special or general 16 bonded warehouse, and which, pursuant to any Act 16 of Congress or proclamation of the President of the 17 United States, can not be lawfully sold or removed 18 from any such warehouse during the period of prohi- 18 bition fixed by such Act or proclamation; and all ware- 80 housing bonds or transportation and warehousing bonds 21 conditioned for the payment of tax on any such spirits 22 so stored on the date such prohibition takes effect 23 shall as to all such spirits actually so stored be can-^ 24 celed and discharged, provided the distiller of such 28 spirits shall in lieu of such bonds and prior to their 28 cancellation execute a bond in a penal sum of not 87 less than $10,000, with sureties satisfactory to the 28 collector of the district, conditioned that the principal 89 shall, during the period of such prohibition, safely 80 keep or cause to be kept in good condition all such 31 spirits and the warehouse in which the same are stored, 32 and shall not remove or suffer to be removed from 33 warehouse, contrary to law, any such spirits during 84 the period of such prohibition ; and the bond herein 35 prescribed shall be in such further sum and shall 88 contain such further conditions as the Commissioner, 87 with the approval of the Secretary, may by regula- 38tions require. The distiller may, subject to the pro- 39 visions of this section, be permitted to retain in any 40 such bonded warehouse distilled spirits on which, under 41 the terms of any existing bond, the tax imposed thereon 48 becomes due and payable prior to the date such pro- 48 hibition takes effect: Provided, That on the removal 44 of such prohibition the distiller shall, as to all spirits 48 as to which the bonded period fixed by law has not 46 expired and which remain stored in warehouse, execute 47 new and satisfactory bond In the form required by 48 existing law, conditioned for the payment of the tax 49 on all such spirits; and all provisions of existing law 60 relating to such bonded warehouses, or the storage 61 of spirits therein, or to the execution of new or addi- 62 tlonal bonds, so far as applicable, shall continue In 63 force as to all distilled spirits rebonded under the 64 provisions of this section. 65 Upon the withdrawal of distilled spirits from bonded 66 warehouse, after the period of prohibition has ended, 57 and under the conditions Imposed by section 50 of an 58 Act entitled "An Act to reduce taxation, to provide 112 revenue for the support of the Government, and for 1 other purposes," approved August 28,,. 1894, an allow- 2 ance for loss by leakage or other unavoidable cause, 3 not exceeding one proof gallon as to packages of a 4 capacity of not less than 40 wine gallons, may be made 6 in addition to that provided in said section 50, as 6 amended; and a like additional allowance of one proof 7 gallon as to each package withdrawn may be made 8 for each period of four months, or fraction thereof, 9 for such spirits as shall have remained in warehouse 10 during the period of prohibition and after the expira- ii > tion of the maximum leakage period fixed by that 12 section. 13 Under regulations prescribed by the Secretary, any 14 imported distilled spirits, wines or other liquors which IB may be in any customs bonded warehouse under the 16 customs laws on, the date such prohibition takes effect 17 shall be permitted to remain therein without payment 18 of any taxes or duties thereon, beyond the three-year 19 period provided in section 2971 of the Revised Statutes, 20 during such period of prohibition ; and may be ex- 21 ported at any time during such extended period. Any 22 imported spirits, wines or other liquors as to which 23 the three-year bonded period may expire after the 24 passage of this Act and prior to the date such pro- 25 hibition takes effect may at the option of the owner 26 remain in bond during such period of prohibition. 27 (c) In lieu of the internal-revenue tax now imposed 28 Perfumes thereon by law there shall be levied and collected upon 29 all perfumes hereafter imported into the United States 30 containing distilled spirits, a tax of $1.10 per wine 31 gallon, and a proportionate tax at a like rate on all 32 fractional parts of such wine gallon. Such tax shall (33 be collected by the collector of customs and deposited 34 as internal-revenue collections, under such rules and 35 regulations as the Commissioner, with the approval of 36 the Secretary, may prescribe. 37 38 SECTION 601. That no distilled spirits produced 39 Importation of after October 3, 1917, shall be imported into the United 40 Distilled States from any foreign country, or from the Virgin 41 Spirits for Islands (unless produced from products the growth 42 Beverage of such Islands, and not then into any State or Terri- 43 Purposes tory or District of the United States in which the 44 Prohibited manufacture or sale of intoxicating liquor is pro- 45 hibited), or from Porto Rico, or the Philippine Islands. 46 Under such rules, regulations, and bonds as the Sec- 47 retary may prescribe, the provisions of this section 48 shall not apply to distilled spirits imported for other 49 than (1) beverage purposes or (2) use in the manu- 50 facture or production of any article used or intended 51 for use as a beverage. 52 53 SECTION 602. That at registered distilleries pro- 54 Regulations for duclng alcohol, or other high-proof spirits, packages 55 Distilleries may be filled with such spirits reduced to not less 56 than one hundred proof from the receiving cisterns 67 and tax paid without being entered into bonded ware- 58 113 1 house. Such spirits may be also transferred from the f receiving cisterns at such distilleries, by means of 8 pipe lines, direct to storage tanks in the bonded ware- 4 house and may be warehoused in such storage tanks. B Such spirits may be also transferred in tanks or tank g cars to general bonded warehouses for storage therein, f either in storage tanks in such warehouses or in the 8 tanks in which they were transferred. Such spirits 9 may also be transferred from receiving cisterns or 10 warehouse storage tanks to barrels, drums, tanks, tank 11 cars, or other approved containers, and may be trans- 12 ported in such containers for exportation or other law- 13 ful purposes. The Commissioner, with the approval 14 of the Secretary, is hereby empowered to prescribe all 15 necessary regulations relating to the drawing off, trans- 18 ferring, gauging, storing, and transporting of such 17 spirits; the records to be kept and returns to be made; 18 the size and kind of packages and tanks to be used; 19 the marking, branding, numbering, and stamping of SO such packages and tanks; the kinds of stamps, if any, 21 to be used; and the time and manner of paying the 22 tax; the kind of bond and the penal sum of same. The 23 tax prescribed by law must be paid before such spirits 24 are removed from the distillery premises, or from 26 general bonded warehouse in the case of spirits trans- 26 ferred thereto, except as otherwise provided by law. 87 Under such regulations as the Commissioner, with 28 the approval of the Secretary, may prescribe, distilled 29 spirits may hereafter be drawn from receiving cis- 30 terns and deposited in distillery warehouses without 31 having affixed to the packages containing the same, 32 distillery warehouse stamps, and such packages, when 38 so deposited in warehouse, may be withdrawn there- 84 from on the original gauge where the same have re- 38 mained In such warehouse for a period not exceeding 88 thirty days from the date of deposit. 87 Under such regulations as the Commissioner, with 88 the approval of the Secretary, may prescribe, the manu- 39 facture, warehousing, withdrawal, and shipment, under 40 the provisions of existing law, of ethyl alcohol for 41 other than (1) beverage purposes or (2) use in the 48 manufacture or production of any article used or in- 48 tended for use as a beverage, and denatured alcohol, 44 may be exempted from the provisions of section 3283 46 of the Revised Statutes. Ethyl 46 The Commissioner, with the approval of the Sec- Alcohol 47 retary, may by regulations exempt distillers of ethyl 48 alcohol, for use in the production of munitions of 48 war, or for other non-beverage purposes, from so much 60 of the provisions of sections 3264, 3285, or 3309 of the 61 Revised Statutes, and Acts amendatory thereof, re- 62 specting the survey of distilleries, the period of fer- 63 mentation, the filling and emptying of fermenting tubs, 64 and assessments, as, in his judgment, may be expedi- 66 ent: Provided, That the bond prescribed in section 66 3260 of the Revised Statutes shall, in the cases herein 67 provided, be In such sum and contain such further 68 conditions as the Commissioner may require, '--^" 114 . SECTION 603. That under such regulations as the 1 Commissioner, with the approval of the Secretary, 8 may prescribe, ethyl alcohol of not less than 180 de- 8 grees proof, produced at any central distilling and 4 denaturing plant established under the provisions of 6 subsection 2, paragraph N, of section IV of the Act 6 entitled "An Act to reduce tariff duties and to provide 7 revenue for the Government, and for other purposes," 8 approved October 3, 1913, may be removed from such 9 plant to any central denaturing bonded warehouse for 10 denaturation, or may, before or after denaturation, be ll removed from such plant or from such denaturing 18 bonded warehouse, free of tax, for use of the United 13 States or for shipment to any nation while engaged 14 against the German Government in the present war is and the removal herein authorized may be made in le such tank vessels, tank cars, drums, casks, or other 17 containers as may be approved by the Commissioner. 18 It shall be lawful, under regulations prescribed by 19 the Commissioner, with the approval of the Secretary, 80 for an allowance to be made for leakage or loss by 81 unavoidable accident and without fault or negligence 88 of the distiller, owner, carrier, or his agents or em- 83 ployees, which may occur during the transportation 84 of such spirits or while the same are lawfully stored 80 on either of the premises herein described. 86 87 SECTION 604. That upon all distilled spirits pro- 88 Floor Tax on duced in or imported into the United States upon which 89 Distilled the internal-revenue tax now imposed by law has been 30 Spirits paid, and which, on the day after the passage of this 31 Act, are held by any person and intended for sale or 38 for use In the manufacture or production of any article 83 intended for sale, there shall be levied, assessed, col- 34 lected, and paid a floor tax of $3.20 (if intended for sale 35 for beverage purposes or for use in the manufacture or 36 production of any article used or intended for use as a 37 beverage) on each proof gallon, and a proportionate tax 38 at a like rate on all fractional parts of such proof 88 gallon. 40 41 SECTION 605. That in addition to the tax imposed 48 Additional Tax by this Act on distilled spirits and wines, there shall 43 on Spirits be levied, assessed, collected, and paid, in lieu of the 44 tax imposed by section 304 of the Revenue Act of 45 1917, a tax of 30 cents on each proof gallon and a 46 proportionate tax at a like rate on all fractional parts 47 of such proof gallon on all distilled spirits or wines 48 hereafter rectified, purified, or refined in such manner, 49 and on all mixtures hereafter produced In such man- 50 ner, that the person so rectifying, purifying, refining, 51 or mixing the same is a rectifier within the meaning 58 of section 3244 of the Revised Statutes, as amended: 53 Provided, That this tax shall not apply to gin pro- 54 duced by the redistillation of a pure spirit over juniper 55 berries and other aromatics. 56 Upon all such articles heretofore produced, and 57 which on the day after the passage of this Act are 68 116 Iheld by any person and intended for sale, there shall 2 be levied, assessed, collected, and paid a floor tax of 3 15 cents on each proof gallon, and a proportionate tax 4 at a like rate on all fractional parts of each proof 6 gallon; and all such distilled spirits so held and not 6 contained in the distillers' original stamped packages, 7 or in bottles or other containers bearing the distillers' 8 original labels, shall for the purpose of this section 9 be regarded as rectified spirits. 10 When the process of rectification is completed and 11 the taxes prescribed by this section have been paid, 12 it shall be unlawful for the rectifier or other dealer 13 to reduce in proof or increase in volume such spirits 14 or wine by the addition of water or other substance; 15 nothing herein contained shall, however, prevent a 16 rectifier from using again in the process of rectification 17 spirits already rectified and upon which the taxes have 18 theretofore been paid. Cordials 19 The taxes imposed by this section shall not attach Liqueurs 20 to cordials or liqueurs on which a tax is imposed and 21 paid under section 611 or 613, nor to the mixing and 22 blending of wines, where such blending is for the sole 23 purpose of perfecting such wines according to com- 24mercial standards, nor to blends made exclusively of 25 two or more pure straight whiskies aged in wood for 26 a period not less than four years and without the 27 addition of coloring or flavoring matter or any other 28 substance than pure water and if not reduced below 29 ninety proof: Provided, That such blended whiskies 30 shall be exempt from tax under this section only when 31 compounded under the immediate supervision of a 32 revenue officer, in such tanks and under such con- 33 ditions and supervision as the Commissioner, with the 34 approval of the Secretary, may prescribe. Uniform 35 All distilled spirits or wines taxable under this Regulations 36 section shall be subject to uniform regulations con- 37cerning the use thereof in the manufacture, blending, 38 compounding, mixing, marking, branding, and sale of 39 whisky and rectified spirits, and no discrimination 40 whatsoever shall be made by reason of a difference 41 in the character of the material from which same may 42 have been produced. 43 The business of a rectifier of spirits shall be car- 44ried on, and the tax on rectified spirits shall be paid, 45 under such rules, regulations, and bonds as may be 48 prescribed by the Commissioner, with the approval of 47 the Secretary. Penalties 48 Whoever violates any of the provisions of this sec- 49tion shall be deemed to be guilty of a misdemeanor BO and, upon conviction, shall be fined not more than 63 $1,000 or Imprisoned not more than two years, and 52 shall. In addition, be liable to double the tax evaded. 53 together with the tax, to be collected by assessment 54 or on any bond given. 65 Stamp 56 SECTION 606. That hereafter collectors shall not Regulations 67 furnish wholesale liquor dealer's stamps In lieu of 68 and in exchange for stamps for rectified spirits unless 116 the package covered by stamp for rectified spirits is 1 to be broken into smaller packages. 2 The Commissioner, with the approval of the Sec- 3 retary, Is authorized to discontinue' the use of the 4 following stamps whenever in his judgment the In- 6 terests of the Government will be subserved thereby: 6 Distillery warehouse, special bonded warehouse, spe- 7 cial bonded rewarehouse, general bonded warehouse, 8 general bonded retransfer, transfer brandy, export 9 tobacco, export cigars, export oleomargarine, and export 10 fermented-liquor stamps. 11 IS SECTION 607. That the Commissioner, with the 13 Installation of approval of the Secretary, is hereby authorized to 14 Facilities for require at distilleries, breweries, rectifying houses, and 15 Protecting wherever else in his judgment such action may be 16 Revenue deemed advisable, the installation of meters, tanks, 17 Required pipes, or any other apparatus for the purpose of pro- 18 tecting the revenue, and such meters, tanks, and pipes 19 and all necessary labor incident thereto shall be at 20 the expense of the person on whose premises the In- 21 stallatlon is required. Any such person refusing or 22 neglecting to install such apparatus when so required 23 by the Commissioner shall not be permitted to con- 24 duct business on such premises. 25 26 SECTION 608. That there shall be levied and col- 27 Tax on Beer, lected on all beer, lager beer, ale, porter, and other 28 Ale, Porter, similar fermented liquor, containing one-half of one 29 Etc. per centum, or more, of alcohol, brewed or manufac- 30 tured and hereafter sold, or removed for consumption 31 or sale, within the United States, by whatever name 32 such liquors may be called. In lieu of the internal- 33 revenue taxes now imposed thereon by law, a tax of 34 $6.00 for every barrel containing not more than thirty- 35 one gallons, and at a like rate for any other quantity 36 or for the fractional parts of a barrel authorized and 37 defined by law, to be collected under the provisions of 38 existing law. 39 40 SECTION 609. That from and after the passage of 41 Removal From this Act taxable fermented liquors may be conveyed 42 Brewery to without payment of tax from the brewery premises 43 Distillery where produced to a contiguous industrial distillery of 44 either class established under the Act entitled "An 45 Act to reduce tariff duties and to provide revenue for 46 the Government, and for other purposes," approved 47 October 3, 1913, to be used as distilling material, and 48 the residue from such distillation, containing less than 49 one-half of 1 per centum of alcohol by volume, which 50 is to be used In making beverages, may be manipulated 51 by cooling, fiavoring, carbonating, settling, and filter- 52 ing on the distillery premises or elsewhere. 53 The removal of the taxable fermented liquor from 54 the brewery to the distillery and the operation of the 55 distillery and removal of the residue therefrom shall 56 be under the supervision of such officer or officers as 57 the Commissioner shall deem proper, and the Com- 68 117 1 missioner, with the approval of the Secretary, I9 here- 8 by authorized to make such regulations from time to 8 time as may be necessary to give force and effect to 4 this section and to safeguard the revenue. 6 8 SECTION 610. That natural wine within the mean- Natural Wine — 6 ing of this Act shall be deemed to be the product made Definition 7 from the normal alcoholic fermentation of the juice 8 of sound, ripe grapes, without addition or abstraction, 10 except such as may occur in the usual cellar treat- 11 ment of clarifying and aging: Provided, however. That 18 the product made from the juice of sound, ripe grapes 18 by complete fermentation of the must under proper 14 cellar treatment and corrected by the addition (under IB the supervision of a ganger or storekeeper-ganger in 18 the capacity of ganger) of a solution of water and 17 pure cane, beet, or dextrose sugar (containing, respec- 18 tively, not less than 95 per centum of actual sugar, 19 calculated on a dry basis) to the must or to the wine, 80 to correct natural deficiencies, when such addition shall 21 not increase the volume of the resultant product more 22 than 35 per centum, and the resultant product does 83 not contain less than five parts per thousand of acid 24 before fermentation and not more than 13 per centum 26 of alcohol after complete fermentation, shall be deemed 26 to be wine within the meaning of this Act, and may 27 be labeled, transported, and sold as "wine," qualified 28 by the name of the locality where produced, and may 29 be further qualified by the name of its own particular 30 type or variety: And provided further. That wine as 31 defined in this section may be sweetened with cane 32 sugar or beet sugar or pure condensed grape must and 33 fortified under the provisions of this Act, and wines 84 so sweetened or fortified shall be considered sweet 85 wine within the meaning of this Act. 87 Still Wines 38 SECTION 611. That upon all still wines, including 89 vermuth, and all artificial or imitation wines or com- 40 pounds sold as still wine, which are hereafter pro- 41 duced In or imported Into the United States, or which 42 on the day after the passage of this Act are on any 43 winery premises or other bonded premises or in transit 44 thereto or at any customhouse, there shall be levied, 45 collected, and paid, in lieu of the Internal-revenue taxes 46 now Imposed thereon by law, taxes at rates as follows, 47 when sold, or removed for consumption or sale: 48 On wines containing not more than 14 per centum 49 of absolute alcohol, 16 cents per wine gallon, the per 60 centum of alcohol taxable under this section to be 61 reckoned by volume and not by weight; 62 On wines containing more than 14 per centum and 68 not exceeding 21 per centum of absolute alcohol, 40 64 cents per wine gallon; 66 On wines containing more than 21 per centum and 66 not exceeding 24 per centum of absolute alcohol, |1 67 per wine gallon; 68 All such wines containing more than 24 per centum 118 of absolute alcohol by volume shall be classed as dis- tilled spirits and shall pay tax accordingly. SECTION 612. That under such regulations and of- ficial supervision and upon the giving of such notices, entries, bonds, and other security as the Commis- sioner, with the approval of the Secretary, may pre- scribe, any producer of wines defined under the pro- visions of this title, may withdraw from any fruit distillery or special bonded warehouse grape brandy, or wine spirits, for the fortification of such wines on the premises where actually made: Provided, That there shall be levied and assessed against the pro- ducer of such wines a tax (in lieu of the internal- revenue tax now imposed thereon by law) of 60 cents per proof gallon of grape brandy or wine spirits when- ever withdrawn and hereafter so used by him in the fortification of such wines during the preceding month, which assessment shall be paid by him within ten months from the date of notice thereof: Provided further, That nothing contained in this section shall be construed as exempting any wines, cordials, liqueurs, or similar compounds from the payment of any tax pro- vided for in this title. SECTION 613. That upon the following articles which are hereafter produced in or Imported into the United States, or which on the day after the passage of this Act are on any winery premises or other bonded premises or In transit thereto or at any customhouse, there shall be levied, collected, and paid taxes at rates as follows, when sold, or removed for consumption or sale: On each bottle or other container of champagne or sparkling wine, 12 cents on each one-half pint or frac- tion thereof: On each bottle or other container of artificially car- bonated wine, 6 cents on each one-half pint or fraction thereof: On each bottle or other container of liqueurs, cor- dials, or similar compounds, by whatever name sold or offered for sale, containing sweet wine fortified with grape brandy, 6 cents on each one-half pint or fraction thereof. The tax Imposed by this section shall, in the case of any article upon which a corresponding internal- revenue tax is now Imposed by law, be in lieu of such tax. SECTION 614. That upon all articles specified In section 611 or 613 upon which the internal-revenue tax now imposed by law has been paid and which are on the day after the passage of this Act held by any person and Intended for sale, there shall be levied, col- lected, and paid a floor tax equal to the difference be- tween the tax imposed by this Act and the tax so paid. SECTION 615. That upon all sweet wines held for sale by the producer thereof upon the day after the Withdrawal From Bond- Regulations Champagne Artificially Carbonated Wine Liqueurs, Cordials See also Sec. 611, 613 Sweet Wines 119 1 passage of this Act there shall be levied, assessed, a collected, and paid a floor tax equivalent to 30 cents • per proof gallon upon the grape brandy or wine spirits 4 used in the fortification of such wine. B Payment of 6 SECTION 616. That the taxes imposed by section Tax 7 611 or 613 shall be paid by stamp on removal of the 8 wines from the customhouse, winery, or other bonded • place of storage for consumption or sale, and every 10 person hereafter producing, or having in his possession H or under his control when this title takes effect, any 18 wines subject to the tax imposed in section 611 or 613 13 shall file such notice, describing the premises on which 14 such wines are produced or stored; shall execute a 18 bond in such form; shall make such inventories under 16 oath; and shall, prior to sale or removal for consump- 17 tion, affix to each cask or vessel containing such wine 18 such marks, labels, or stamps as the Commissioner, 19 with the approval of the Secretary, may from time 80 to time prescribe; and the premises described in such 21 notice shall, for the purpose of this Act, be regarded 22 as bonded premises. But the provisions of this sec- 23 tion, except as to payment of tax and the affixing of 24 the required stamps or labels, shall not apply to wines 25 held by retail dealers, as defined in section 3244 of 26 the Revised Statutes, nor, subject to regulations pre- 27 scribed by the Commissioner, with the approval of 28 the Secretary, shall the tax imposed by section 611 29 apply to wines produced for the family use of the 30 duly registered producer thereof and not sold or other- 31 wise removed from the place of manufacture and not 38 exceeding in any case two hundred gallons per year. 33 84 SECTION 617. That sections 42, 43, and 45 of the 35 Act entitled "An Act to reduce the revenue and equal- 86 ize duties on imports, and for other purposes," ap- 87 proved October 1, 1890, as amended by section 68 of 38 the Act entitled "An Act to reduce taxation, to provide 88 revenue for the Government and for other purposes," 40 approved August 27, 1894, are further amended to read 41 as follows: Sweet Wines 42 "Section 42. That any producer of pure sweet wines 48 may use in the preparation of such sweet wines, under 44 such regulations and after the filing of such notices 48 and bonds, together with the keeping of such records 48 and the rendition of such reports as to materials and 47 products as the Commissioner of Internal Revenue, 48 with the approval of the Secretary of the Treasury, 40 may prescribe, wine spirits produced by any duly au- 50 thorized distiller, and the Commissioner of Internal 51 Revenue, In determining the liability of any distiller 58 of wine spirits to assessment under section 3309 of the 58 Revised Statutes, is authorized to allow such distiller 54 credit In his computations for the wine spirits with- 55 drawn to be used in fortifying ^weet wines under this 56 Act. Wine Spirits 57 "Section 43. That the wine spirits mentioned in 68 section 42 is the product resulting from the dlstllla- 120 tion of fermented grape juice, to which water may have 1 been added prior to, during, or after fermentation, for 2 the sole purpose of facilitating the • fermentation and 3 economical distillation thereof, and shall be held to 4 include the product from grapes or their residues com- 5 monly known as grape brandy, and shall include com- 6 mercial grape brandy which may have been colored 7 with burnt sugar or caramel; and the pure sweet wine 8 which may be fortified with wine spirits under the 9 provisions of this Act is fermented or partially fer- 10 mented grape juice only, with the usual cellar treat- H ment, and shall contain no other substance whatever 12 introduced before, at the time of, or after fermenta- 13 tion, except as herein expressly provided: Provided, 14 That the addition of pure boiled or condensed grape 15 must or pure crystallized cane or beet sugar, or pure 16 dextrose sugar containing, respectively, not less than 17 95 per centum of actual sugar, calculated on a dry 18 basis, or water, or any or all of them, to the pure 19 grape juice before fermentation, or to the fermented 20 product of such grape juice, or to both, prior to the 21 fortification herein provided for, either for the pur- 22 pose of perfecting sweet wines according to commer- 23 cial standards or for mechanical purposes, shall not 24 be excluded by the definition of pure sweet wine afore- 25 said: Provided, however. That the cane or beet sugar, 26 or pure dextrose sugar added for sweetening purposes 27 shall not be in excess of 11 per centum of the weight 28 of the wine to be fortified: And provided further. That 29 the addition of water herein authorized shall be under 30 such regulations as the Commissioner of Internal Rev- 31 enue, with the approval of the Secretary of the Treas- 32 ury, may from time to time prescribe : Provided, how- 33 ever. That records kept in accordance with such regu- 34 lations as to the percentage of saccharine, acid, alco- 35 holic, and added water content of the wine offered for 36 fortification shall be open to inspection by any official 37 of the Department of Agriculture thereto duly author- 38 ized by the Secretary of Agriculture; but in no case 39 shall such wines to which water has been added be 40 eligible for fortification under the provisions of this 41 Act, w^here the same, after fermentation and before 42 fortification, have an alcoholic strength of less than 43 5 per centum of their volume. 44 "Section 45. That under such regulations and of- 45 ficial supervision, and upon the execution of such en- 46 tries and the giving of such bonds, bills of lading, and 47 other security as the Commissioner of ^ Internal Rev- 48 enue, with the approval of the Secretary of the Treas- 49 ury, shall prescribe, any producer of pure sweet wines 50 as defined by this Act may withdraw wine spirits from 51 any special bonded warehouse in original packages or 52 from any registered distillery in any quantity not less 53 than eighty wine gallons, and may use so much of the 54 same as may be required by him under such regula- 55 tiong, and after the filing of such notices and bonds 56 and the keeping of such records and the rendition of 57 such reports as to materials and products and the 58 121 Removal of Wines Prom Winery 1 disposition of the same as the Commissioner of In- 3 ternal Revenue, with the approval of the Secretary 3 of the Treasury, shall prescribe, In fortifying the pure 4 sweet wines made by him, and for no other purpose, B In accordance with the foregoing limitations and pro- • visions; and the Commissioner of Internal Revenue, 7 with the approval of the Secretary of the Treasury, Is elauthorized whenever he shall deem It to be necessary for the prevention of violations of this law to pre- 10 scribe that wine spirits withdrawn under this section 11 shall not be used to fortify wines except at a certain 12 distance prescribed by him from any distillery, rec- 13 tifying house, winery, or other establishment used for producing or storing distilled spirits, or for making or storing wines other than wines which are so for- lejtlfied, and that in the building in which such forti- fication of wines is practiced no wines or spirits other than those permitted by this regulation shall be stored in any room or part of the building In which forti- fication of wines is practiced. The use of wine spirits Orape Wines 19 80 21 for the fortification of sweet wines under this Act 22||shall be under the immediate supervision of an officer of Internal revenue, who shall make returns describing 243the kinds and quantities of wine so fortified, and shall 25JafCix such stamps and seals to the packages containing such wines as may be prescribed by the Commissioner arjof Internal Revenue, with the approval of the Secre- 28|tary of the Treasury: and the Commissioner of In- M ternal Revenue, with the approval of the Secretary of 30 the Treasury, shall provide by regulations the time 31 within which wines so fortified with the wine spirits 38 so withdrawn may be subject to inspection, and for 33 final accounting for the use of such wine spirits and 34 for rewarehousing or for payment of the tax on any 88 portion of such wine spirits which remain not used 88 in fortifying pure sweet wines." 37 38 SECTION 618. (a) That under such regulations and .39 upon the execution of such notices, entries, bonds, and 40 other security as the Commissioner, with the approval 41 of the Secretary, may prescribe, domestic wines sub- 48 ject to the tax Imposed by section 611 may be removed 43 from the winery where produced, free of tax, for stor- 44 age on other bonded premises or from such premises 45 to other bonded premises (but not more than one such 48 additional removal shall be allowed), or for exporta- 4T tlon from the United States or for use as distilling ma- 48terial at any regularly registered distillery: Provided. 48 however. That the distiller using any such wine as ma- 80 terial shall, subject to the provisions of section 3309 61 of the Revised Statutes, as amended, be held to pay 68 the tax on the product of such wines as will Include 63 both the alcoholic strength therein produced by fer- 64 mentation and that obtained from the brandy or wine 66 spirits added to such wines at the time of fortification. 68 (b) Under regulations prescribed by the Commis- 67sloner with the approval of the Secretary, it shall be 68 lawful to produce grape wines on bpnded winery prem- 123 ises by the usual method, and to transport and use 1 the same, and like wines heretofore produced and now 8 stored on bonded winery premises, as distilling mate- • rial for the production of nonbeverage spirits In the 4 production of nonalcoholic wines, containing less than 6 % of 1 per centum of alcohol by volume. In any fruit • brandy or industrial distillery: Provided, That all 7 alcoholic spirits so obtained at any industrial distillery 8 shall be denatured, and all spirits so obtained at any 8 fruit distillery shall be removed and used only for non- 10 beverage purposes or for denaturatlon. 11 la SECTION 619. That the collection of the tax on Im- 13 Imported ported still wines, including vermuth, and sparkling 14 Wines wines, Including champagne, and on imported liqueurs, 18 cordials, and similar compounds, may be made within 16 the discretion of the Commissioner, with the approval 17 of the Secretary, by assessment Instead of by stamps. 18 19 SECTION 620. That whoever evades or attempts to 20 Penalties evade any tax Imposed by sections 611 to 615, both 81 Inclusive, or any requirement of sections 610 to 621, 28 both inclusive, or regulation Issued pursuant thereto, 23 or whoever, otherwise than as provided in such sec- 24 tions, recovers or attempts to recover any spirits from 25 domestic or Imported wine, or whoever rectifies, mixes, 26 or compounds with distilled spirits any domestic wines, 27 other than In the manufacture of liqueurs, cordials, or 28 similar compounds, shall, on conviction, be punished 29 for each such offense by a fine of not exceeding $5,000, 30 or Imprisonment for not more than five years, or both, 31 and in addition thereto by a penalty of double the tax 32 evaded, or attempted to be evaded, to be assessed and 33 collected in the same manner as taxes are assessed 34 and collected, and all wines, spirits, liqueurs, cordials, 35 or similar compounds as to which such violation occurs 36 shall be forfeited to the United States. But the pro- 37 visions of this section and the provisions of section 38 3244 of the Revised Statutes, as amended, relating to 39 rectification, or other Internal-revenue laws of the 40 United States, shall not be held to apply to or prohibit 41 the mixing or blending of wines subject to tax under 43 the provisions of sections 611 to 615, both inclusive, 43 with each other or with other wines for the sole pur- 44 pose of perfecting such wines according to commercial 45 standards: Provided, That nothing herein contained 46 shall be construed as prohibiting the use of tax-paid 47 grain or other ethyl alcohol In the fortification of sweet 48 wines as defined In section 610 of this Act and section 49 43 of the Act entitled "An Act to reduce the revenue 50 and equalize duties on Imports, and for other purposes," 51 approved October 1, 1890, as amended by this Act. 52 53 SECTION 621. That the Commissioner, by regula- 54 Apparatus and tions to be approved by the Secretary, may require the 55 Gangers use at each fruit distillery of such spirit meters, and 56 such locks and seals to be affixed to fermenters, tanks, 57 or other vessels and to such pipe connections as may 68 183 Loss While in Storage Mash Beer Regulations for Manufacture Withdrawal From Receiving Cistern for Export 1 in his Judgment be necessary or expedient, and Is here- 2 by authorized to assign to any such distillery and to 3 each winery where wines are to be fortified such num- 4 ber of gangers or storekeeper-gangers in the capacity 6 of gangers as may be necessary for the proper super- 6 vision of the manufacture of brandy or the making or 7 fortifying of wines subject to tax imposed by this sec- Stion; and the compensation of such officers shall not 9 exceed $5 per diem while so assigned, together with 10 their actual and necessary traveling expenses, and also 11 a reasonable allowance for their board bills, to be fixed 12 by the Commissioner, with the approval of the Secre- 13 tary, but not to exceed $2.50 per diem for such board 14 bills. 15 16 SECTION 622. That the Commissioner, with the ap- 17 proval of the Secretary, is hereby authorized to make 18 such allowances for unavoidable loss of wines while 19 on storage or during cellar treatment as in his Judg- 20 ment may be just and proper. 21 22 SECTION 623. That the second paragraph of section 23 3264 of the Revised Statutes, as amended by section 24 5 of the Act of March 1, 1879, and as further amended 25 by the Act of June 22, 1910, be amended so as to read 26 as follows: 27 "In all surveys forty-five gallons of mash or beer 28 brewed or fermented from grain shall represent not 29 less than one bushel of grain, and seven gallons of 30 mash or beer brewed or fermented from molasses shall 31 represent not less than one gallon of molasses, except 32 in distilleries operated on the sour-mash principle, in 33 which distilleries sixty gallons of beer brewed or fer- 34 mented from grain shall represent not less than one 35 bushel of grain, and except that in distilleries where 36 the filtration-aeration process is used, with the ap- 37 proval of the Commissioner of Internal Revenue; that 38 is, where the mash after it leaves the mash tub Is 39 passed through a filtering machine before it is run into 40 the fermenting tub, and only the filtered liquor passes 41 into the fermenting tub, there shall hereafter be no 42 limitation upon the number of gallons of water which 43 may be used in the process of mashing or filtration for 44 fermentation; but the Commissioner of Internal Rev- 45 enue, with the approval of the Secretary of the Treas- 46 ury, in order to protect the revenue, shall be authorized 47 to prescribe by regulation, to be made by him, such 48 character of survey as he may find suitable for distil- 49 leries using such filtration-aeration process. The provi- so sions hereof relating to filtration-aeration process shall 51 apply only to sweet-mash distilleries." 52 53 SECTION 624. That under such regulations as the 54 Commissioner, with the approval of the Secretary, may 55 prescribe, alcohol or other distiiled spirits of a proof 56 strength of not less than one hundred and eighty de- 57 grees intended for export free of tax may be drawn §8 from receiving cisterns at any distillery, or from stor- 124 age tanks in any distillery warehouse, for transfer to 1 tanks or tank cars for export from the United States, 3 and all provisions of existing law relating to the 3 exportation of distilled spirits not inconsistent herewith 4 shall apply to spirits removed for export under the pro- 6 visions of this Act. 6 7 SECTION 625. That section 3255 of the Revl&ed 8 Statutes as amended by the Act of June 3, 1896, and as 9 further amended by the Act of March 2, 1911, be further XO amended so as to read as follows: 11 12 "Section 3255. The Commissioner of Internal Reve- 13 Brandy nue, with the approval of the Secretary of the Treas- 14 ury, may exempt distillers of brandy made exclu- 15 sively from apples, peaches, grapes, pears, pineapples, 16 oranges, apricots, berries, plums, pawpaws, persimmons, 17 prunes, figs, or cherries from any provision of this title 18 relating to the manufacture of spirits, except as to the 19 tax thereon, when in his judgment it may seem ex- 20 pedient to do so: Provided, That where. In the manu- 21 f acture of wine, artificial sweetening has been used the 22 wine or the fruit pomace residuum may be used in the 23 distillation of brandy, and such use shall not prevent 24 the Commissioner of Internal Revenue, with the ap- 25 proval of the Secretary of the Treasury, from exempt- 26 ing such distiller from any provision of this title relat- 27 ing to the manufacture of spirits, except as to the tax 28 thereon, when in his judgment it may seem expedient 29 to do so: And provided further. That the distillers 30 mentioned in this section may add to not less than five 31 hundred gallons (or ten barrels) of grape cheese not 32 more than five hundred gallons of a sugar solution 33 made from cane, beet, starch, or corn sugar, 95 per 34 centum pure, such solution to have a saccharine 35 strength of not to exceed 10 per centum, and may fer- 36 ment the resultant mixture on a winery or distillery 37 premises, and such fermented product shall be regarded 38 as distilling material." 39 40 SECTION 626. That distilled spirits known commer- 41 Gin cially as gin of not less than 80 per centum proof may 42 at any time within eight years after entry In bond at 43 any distillery be bottled In bond at such distillery for 44 export without the payment of tax, under such rules 45 and regulations as the Commissioner, with the approval 46 of the Secretary, may prescribe. 47 48 SECTION 627. That section 3354 of the Revised 49 Statutes as amended by the Act approved June 18, 1890, 50 be and is hereby, amended to read as follows: 51 52 "Section 3354. Every person who withdraws any 53 Penalties fermented liquor from any hogshead, barrel, keg, or 54 other vessels upon which the proper stamp has not 55 been affixed for the purpose of bottling the same, or 56 who carries on or attempts to carry on the business of 57 bottling fermented liquor in any brewery or other place 68 125 & in which fermented liquor Is made, or upon any prem- illses having communication with such brewery, or any 3 warehouse, shall be liable to a fine of $500, and the prop- 4 erty used In such bottling or business shall be liable to 6 forfeiture: Provided, however. That this section shall 6 not be construed to prevent the withdrawal and trans- 7 fer of unfermented, partially fermented, or fermented 8 liquors from any of the vats in any brewery by way 8 of a pipe line or other conduit to another building or 10 place for the sole purpose of bottling the same, such 11 pipe line or conduit to be constructed and operated in 12 such manner and with such cisterns, vats, tanks, valves, 13 cocks, faucets, and gauges, or other utensils or appa- 14 ratus, either on the premises of the brewery or the 15 bottling house, and with such changes of or additions 16 thereto, and such locks, seals, or other fastenings, and 17 under such rules and regulations as shall be from 18 time to time prescribed by the Commissioner of In- 19 ternal Revenue, subject to the approval of the Secre- 20 tary of the Treasury, and all locks and seals prescribed 21 shall be provided by the Commissioner of Internal Kev- 22 enue at the expense of the United States: Provided 23 further, That the tax imposed in section 3339 of the 24 Revised Statutes shall be paid on all fermented liquor 28 removed from a brewery to a bottling house by means 26 of a pipe or conduit, at the time of such removal, by the 27 cancellation and defacement, by the collector of the 28 district or his deputy, in the presence of the brewer, 29 of the number of stamps denoting the tax on the fer- 30 mented liquor thus removed. The stamps thus can- 31 celed and defaced shall be disposed of and accounted for 32 in the manner directed by the Commissioner of Internal 33 Revenue, with the approval of the Secretary of the 34 Treasury. And any violation of the rules and regula- 38 tions hereafter prescribed by the Commissioner of 36 Internal Revenue, with the approval of the Secretary 37 of the Treasury, in pursuance of these provisions, shall 38 be subject to the penalties above provided by this sec- 39 tlon. Every owner, agent, or superintendent of any 40 brewery or bottling house who removes, or connives at 41 the removal of, any fermented liquor through a pipe 42 line or conduit, without payment of the tax thereon, or 48 who attempts in any manner to defraud the revenue 44 as above, shall forfeit all the liquors made by and for 45 him, and all the vessels, utensils, and apparatus used 46 in making the same." 47 Other 48 SECTION 628. That there shall be levied, assessed, Beverages 49 collected, and paid in lieu of the taxes imposed by Derived From 60 sections 313 and 315 of the Revenue Act of 1917 — Cereals 61 (a) Upon all beverages derived wholly or in part 62 from cereals or substitutes therefor, and containing less 68 than one-half of one per centum of alcohol, sold by 64 the manufacturer, producer, or importer, in bottles or 66 other closed containers, a tax equivalent to 15 per Soft Drinks 66 centum of the price for which so sold; and upon all 67 unfermented grape juice, ginger ale, root beer, sarsa- 68 parilla, pop, artificial mineral waters (carbonated or 196 not carbonated), other carbonated waters or beverages. 1 and other soft drinks, sold by the manufacturer, pro- 3 ducer, or importer, in bottles or other closed containers, 3 a tax equivalent to 10 per centum of the price for 4 which so sold; and 5 '] (b) Upon all natural mineral waters or table waters, 6 sold by the producer, bottler, or importer thereof, in 7 ; bottles or other closed containers, at over 10 cents per 8 gallon, a tax of 2 cents per gallon. 9 10 SECTION 629. That each manufacturer, producer, 11 Monthly bottler, or Importer of any of the articles enumerated in 12 Return and section 628 shall make monthly returns under oath in 13 Payment of duplicate and pay the taxes imposed in respect to such 14 Tax articles by such section to the collector for the district 15 in which is located the principal place of business, con- 16 taining such information necessary for the assessment 17 of the tax, and at such times and In such manner as 18 the Commissioner, with the approval of the Secretary, 19 may by regulation prescribe. 20 The tax shall, without assessment by the Commis- 21 sioner or notice from the collector, be due and payable 22 to the collector at the time so fixed for filing the re- 23 turn. If the tax Is not paid when due, there shall be 24 added as part of the tax a penalty of 5 per centum, 25 together with interest at the rate of 1 per centum for 26 each full month, from the time when the tax became 27 due. 28 29 SECTION 630. That on and after May 1, 1919, there 30 Ice Cream shall be levied, assessed, collected, and paid a tax of 31 Parlors, Soda 1 cent for each 10 cents or fraction thereof of the 32 Fountains, amount paid to any person conducting a soda fountain, 33 Soft Drinks ice-cream parlor, or other similar place of business, for 34 drinks commonly known as soft drinks, compounded 85 or mixed at such place of business, or for ice cream, 86 ice-cream sodas, sundaes, or other similar articles of 37 food or drink, when any of the above are sold on or 38 after such date for consumption in or in proximity to 39 such place of business. Such tax shall be paid by the 40 purchaser to the vendor at the time of the sale and 41 shall be collected, returned, and paid to the United 42 States by such vendor in the same manner as provided 43 in section 502. 44 45 TITLE VII.— TAX ON CIGARS, TOBACCO AND ^7 MANUFACTURES THEREOF. 48 49 SECTION 700. (a) That upon cigars and cigarettes 50 Cigars and manufactured in or Imported into the United States, 51 Cigarettes and hereafter sold by the manufacturer or importer, 62 or removed for consumption or sale, there shall be 63 levied, collected, and paid under the provisions of 64 existing law, in lieu of the internal-revenue taxes now 55 Imposed thereon by law, the following taxes, to be 56 paid by the manufacturer or importer thereof— 57 On cigars of all descriptions made of tobacco, or 58 Cigars 127 Cigarettes Tobacco, Snuff any substitute therefor, and weighing not more man three pounds per thousand, $1.50 per thousand; On cigars made of tobacco, or any substitute therefor, and weighing more than three pounds per thousand, if manufactured or imported to retail at not more than 5 cents each. $4 per thousand; If manufactured or imported to retail at more than 5 cents each and not more than 8 cents each, $6 per thousand; If manufactured or imported to retail at more than than 8 cents each and not more than 15 cents each, $9 per thousand; If manufactured or imported to retail at more than 15 cents each and not more than 20 cents each, $12 per thousand; Tf manufactured or irnpbrted to retail at more than 20 cents each, $15 per thousand; On cigarettes made of tobacco, or any substitute therefor, and weighing not more than three pounds per thousand, $3 per thousand; Weighing more than three pounds per thousand, $7.20 per thousand. (b) Whenever in this section reference Is made to cigars manufactured or imported to retail at not over a certain price each, then In determining the tax to be paid regard shall be had to the ordinary retail price of a single cigar. (c) The Commissioner may, by regulation, require the manufacturer or Importer to affix to each box, package, or container a conspicuous label indicating the clause of this section under which the cigars therein con- tained have been tax-paid, which must correspond with the tax-paid stamp on such box or container. (d) Every manufacturer of cigarettes (including small cigars weighing not more than three pounds per thousand) shall put up all the cigarettes and such small cigars that he manufactures or has manufactured for him, and sells or removes for consumption or sale, in packages or parcels containing five, eight, ten, twelve, fifteen, sixteen, twenty, twenty-four, forty, fifty, eighty, or one hundred cigarettes each, and shall securely affix to each of such packages or parcels a suitable stamp denoting the tax thereon and shall prop- erly cancel the same prior to such sale or removal for consumption or sale under such regulations as the Commissioner, with the approval of the Secretary, shall prescribe; and all cigarettes imported from a foreign country shall be packed, stamped, and the stamps can- celed in a like manner, in addition to the import stamp Indicating inspection of the custom house before they are withdrawn therefrom. SECTION 701. (a) That upon all tobacco and snuff manufactured in or imported into the United States, and hereafter sold by the manufacturer or importer, or re- moved for consumption or sale, there shall be levied, collected, and paid, in lieu of the Internal-revenue taxes now Imposed thereon by law, a tax of 18 cents per 128 pound, to be paid by the manufacturer or importer 1 thereof. 2 (b) Section 3362 of the Revised Statutes, as amended. 3 is hereby amended to read as follows:, 4 6 "Section 3362. All manufactured tobacco shall be 6 Regulation of put up and prepared by the manufacturer for sale, or 7 Packages removal for sale or consumption, in packages of the 8 following description and in no other manner: 9 "All smoking tobacco, snuff, fine-cut chewing tobacco, 10 all cut and granulated tobacco, all shorts, the refuse 11 of fine-cut chewing, which has passed through a riddle 12 of thirty-six meshes to the square inch, and all refuse 13 scraps, clippings, cuttings, and sweepings of tobacco, 14 and all other kinds of tobacco not otherwise provided 15 for, in packages containing one-eighth of an ounce, 16 three-eighths of an ounce, and further packages with a 17 difference between each package and the one next small- 18 er of one-eighth of an ounce up to and including two 19 ounces, and further packages with a difference between 20 each package and the one next smaller of one-fourth of 21 an ounce up to and including four ounces, and packages 22 of five ounces, six ounces, seven ounces, eight ounces, 23 ten ounces, twelve ounces, fourteen ounces, and sixteen 24 ounces: Provided, That snuff may, at the option of the 25 manufacturer, be put up in bladders and in jars con- 26 taining not exceeding twenty pounds. 27 "All cavendish, plug, and twist tobacco, in wooden 28 packages not exceeding two hundred pounds net weight. 29 "And every such wooden package shall have printed 30 or marked thereon the manufacturer's name and place 31 of manufacture, the registered number of the manu- 32 factory, and the gross weight, the tare, and the net 33 weight of the tobacco in each package: Provided, That 34 these limitations and descriptions of packages shall 35 not apply to tobacco and snuff transported in bond for 36 exportation and actually exported: And provided fur- 37 ther. That perique tobacco, snuff flour, fine-cut shorts, 38 the refuse of fine-cut chewing tobacco, refuse scraps, 39 clippings, cuttings, and sweepings of tobacco, may be 40 sold in bulk as material, and without the payment of 41 tax, by one manufacturer directly to another manufac- 42 turer, or for export, under such restrictions, rules, and 43 regulations as the Commissioner of Internal Revenue 44 may prescribe: And provided further. That wood, metal, 45 paper, or other materials may be used separately or in 46 combination for packing tobacco, snuff, and cigars, un-47 der such regulations as the Commissioner of Internal 48 Revenue may establish." 49 50 SECTION 702. That upon all the articles enumerated 51 Floor Tax on in section 700 or 701, which were manufactured or 52 Tobacco and imported, and removed from factory or customhouse 53 Tobacco on or prior to the date of the passage of this Act, and 54 Products upon which the tax imposed by existing law has been 55 paid, and which are, on the day after the passage of this 56 Act, held by any person and intended for sale, there 57 shall be levied, assessed, collected, and paid a floor tax 58 129 1 equal to the difference between (a) the tax imposed by 8 this Act upon such articles according to the class in 8 which they are placed by this title, and (b) the tax Im- 4 posed upon such articles by existing law other than 6 section 403 of the Revenue Act of 1917. • Cigarette 7 SECTION 703. That there shall be levied, collected. Paper 8 and paid, in lieu of the taxes imposed by section 404 8 of the Revenue Act of 1917, upon cigarette paper made 10 up Into packages, books, sets, or tubes, made up in or 11 imported into the United States and hereafter sold by 12 the manufacturer or importer to any person (other than 13 to a manufacturer of cigarettes for use by him in the 14 manufacture of cigarettes) the following taxes, to be 15 paid by the manufacturer or importer: On each package, 10 book, or set, containing more than twenty-five but not 17 more than fifty papers, y2 cent; containing more than 18 fifty but not more than one hundred papers, 1 cent; 18 containing more than one hundred papers, % cent for 80 each fifty papers or fractional part thereof; and upon 21 tubes, 1 cent for each fifty tubes or fractional part 22 thereof. 23 Every manufacturer of cigarettes purchasing any 24 cigarette paper made up into tubes (a) shall give bond 25 in an amount and with sureties satisfactory to the Com- 28 missioner that he will use such tubes in the manufac- 87 ture of cigarettes or pay thereon a tax equivalent to the 28 tax Imposed by this section, and (b) shall keep such 28 records and render under oath such returns as the Com- 80 missioner finds necessary to show the disposition of all 31 tubes purchased or imported by such manufacturer of 38 cigarettes. Repeal of Sec. 34 35 of Act of 35 Aug. 5, 1909 36 37 40 41 Regulations for 42 Dealers in 43 Leaf Tobacco 44 46 48 47 48 48 60 61 62 63 64 66 60 67 SECTION 704. That section 35 of the Act entitled "An Act to provide revenue, equalize duties and encour- age the Industries of the United States, and for other purposes," approved August 5, 1909, be, and is hereby, repealed, to take effect April 1, 1919. That section 3360 of the Revised Statutes be, and is hereby, amended to read as follows: "Section 3360. (a) Every dealer in leaf tobacco shall file with the collector of the district in which his business is carried on, a statement in duplicate, sub- scribed under oath, setting forth the place, and if In a city, the street and number of the street, where his business Is to be carried on, and the exact location of each place where leaf tobacco is held by him on storage, and, whenever he adds to or discontinues any of his leaf tobacco storage places, he shall give immediate notice to the collector of the district In which he Is registered. "Every such dealer shall give a bond with surety, sat- isfactory to, and to be approved by, the collector of the district, In such penal sum as the collector may require, not less than $500; and a new bond may be required in the discretion of the collector or under instructions of the Commissioner. "Every such dealer shall be assigned a number by 130 the collector of the district, which number shall appear 1 In every inventory, invoice and report rendered by the 2 dealer, who shall also obtain certificates from the col- 8 lector of the district setting forth the place where his 4 business Is carried on and the places designated by B the dealer as the places of storage of his tobacco, which 6 certificates shall be posted conspicuously within the 7 dealer's registered place of business, and within each 8 designated place of storage. 9 "(b) Every dealer in leaf tobacco shall make and 10 deliver to the collector of the district a true inventory 11 of the Quantity of the different kinds of tobacco held 12 or owned, and where stored by him, on the first day of 13 January of each year, or at the time of commencing 14 and at the time of concluding business, if before or 15 after the first day of January, such inventory to be 16 made under oath and rendered in such form as may 17 be prescribed by the Commissioner. 18 "Every dealer in leaf tobacco shall render such 19 invoices and keep such records as shall be prescribed 20 by the Commissioner, and shall enter therein, day by 21 day, and upon the same day on which the circum- 22 stance, thing or act to be recorded is done or occurs, 23 an accurate account of the number of hogsheads, 24 tierces, cases and bales, and quantity of leaf tobacco 25 contained therein, purchased or received by him, on 26 assignment, consignment, for storage, by transfer or 27 otherwise, and of whom purchased or received, and the 28 number of hogsheads, tierces, cases and bales, and 29 the quantity of leaf tobacco contained therein, sold 30 by him, with the name and residence in each instance 31 of the person to whom sold, and if shipped, to whom 32 shipped, and to what district; such records shall be 33 kept at his place of business at all times and pre- 34 served for a period of two years, and the same shall 35 be open at all hours for the Inspection of any Internal- 36 revenue officer or agent. 37 "Every dealer in leaf tobacco on or before the tenth 38 day of each month, shall furnish to the collector of 39 the district a true and complete report of all pur- 40 chases, receipts, sales and shipments of leaf tobacco 41 made by him during the month next preceding, which 42 report shall be verified and rendered in such form as 43 the Commissioner, with the approval of the Secretary, 44 shall prescribe. 45 "(c) Sales or shipments of leaf tobacco by a dealer 46 in leaf tobacco shall be in quantities of not less than 47 a hogshead, tierce, case, or bale, except loose leaf 48 tobacco comprising the breaks on warehouse floors, 49 and except to a duly registered manufacturer of cigars 50 for use in his own manufactory exclusively. 51 "Dealers in leaf tobacco shall make shipments of 52 leaf tobacco only to other dealers In leaf tobacco, to 53 registered manufacturers of tobacco, snuff, cigars or 54 cigarettes, or for export. 55 "(d) Upon all leaf tobacco sold, removed or shipped 56 by any dealer in leaf tobacco in violation of the pro- 57 visions of subdivision (c), or in respect to which no 58 131 1 report has been made by such dealer in accordance S with the provisions of subdivision (b), there shall be 8 levied, assessed, collected and paid a tax equal to the 4 tax then in force upon manufactured tobacco, such tax 5 to be assessed and collected in the same manner as e the tax on manufactured tobacco. Penalties 7 "(e) Every dealer in leaf tobacco 8 "(1) who neglects or refuses to furnish the state- 8 ment, to give bond, to keep books, to file inventory or 10 to render the invoices, returns or reports required by 11 the Commissioner, or to notify the collector of the 12 district of additions to his places of storage; or 13 "(2) who ships or delivers leaf tobacco, except as 14 herein provided; or 16 "(3) who fraudulently omits to account for tobacco 16 purchased, received, sold, or shipped; 17 shall be fined not less than $100 or more than $500, or 18 imprisoned not more than one year, or both. 19 "(f) For the purposes of this section a farmer or 20 grower of tobacco shall not be regarded as a dealer in 21 leaf tobacco in respect to the leaf tobacco produced 22 by him." 24 2B TITLE VIIL—TAX ON ADMISSIONS AND DUES. 88 27 SECTION 800. (a) That from and after April 1, 28 1919, there shall be levied, assessed, collected, and paid, 29 in lieu of the taxes imposed by section 700 of the 30 Revenue Act of 1917 — 10% Tax 31 (1) A tax of 1 cent for each 10 cents or fraction 38 thereof of the amount paid for admission to any place 33 on or after such date, including admission by season 34 ticket or subscription, to be paid by the person paying 35 for such admission; Persons 36 (2) In the case of persons (except bona fide employees, Admitted 37 municipal officers on oflEicial business, persons in the Free or at 38 military or naval forces of the United States when in Reduced 39 uniform, and children under twelve years of age) ad- Rates 40 mitted free or at reduced rates to any place at a time 41 when and under circumstances under which an admis- 42 sion charge is made to other persons, a tax of 1 cent 43 for each 10 cents or fraction thereof of the price so 44 charged to such other persons for the same or similar 45 accommodations, to be paid by the person so admitted; Theatres, 46 (3) Upon tickets or cards of admission to theatres, Operas 47 operas, and other places of amusement, sold at news 48 stands, hotels, and places other than the ticket offices 49 of such theatres, operas, or other places of amuse- 60 ment, at not to exceed 50 cents in excess of the sum 61 of the established price therefor at such ticket offices 62 plus the amount of any tax imposed under paragraph 63 (1), a tax equivalent to 5 per centum of the amount 64 of such excess; and if sold for more than 50 cents in 66 excess of the sum of such established price plus the 66 amount of any tax imposed under paragraph (1), a 67 tax equivalent to 50 per centum of the whole amount 68 of such excess, such taxes to be returned and paid, 132 in the manner provided in section 903, by the person 1 selling such tickets; 2 (4) A tax equivalent to 50 per centum of the amounts 50% Tax on for which the proprietors, managers, or employees of 4 Tickets Sold any opera house, theater, or other place of amusement 5 Above sell or dispose of tickets or cards of admission in 6 Regular Price excess of the regular or established price or charge 7 therefor, such tax to be returned and paid, in the 8 manner provided in section 903, by the person selling 9 such tickets; 10 (5) In the case of persons having the permanent use 11 Boxes or Seats of boxes or seats in an opera house or any place of 12 Permanently amusement or a lease for the use of such box or seat 13 Leased in such opera house or place of amusement (in lieu of 14 the tax imposed by paragraph (1)), a tax equivalent to 15 10 per centum of the amount for which a similar box 16 or seat is sold for each performance or exhibition at 17 which the box or seat is used or reserved by or for 18 the lessee or holder, such tax to be paid by the lessee 19 or holder; and 20 (6) A tax of 1% cents for each 10 cents or fraction 21 Roof Gardens, thereof of the amount paid for admission to any public 22 Cabarets performance for profit at any roof garden, cabaret, 23 or other similar entertainment, to which the charge for 24 admission is wholly or in part included in the price 25 paid for refreshment, service, or merchandise; the 26 amount paid for such admission to be deemed to be 27 20 per centum of the amount paid for refreshment, 28 service, and merchandise; such tax to be paid by the 29 person paying for such refreshment, service, or mer- 30 chandise. 31 (b) No tax shall be levied under this title in respect 32 Religious, to any admissions all the proceeds of which inure 33 Charitable, exclusively to the benefit of religious, educational, or 34 Educational, charitable institutions, societies, or organizations, so- 35 Etc., cieties for the prevention of cruelty to children or 36 Entertain- animals, or exclusively to the benefit of organizations 37 ments conducted for the sole purpose of maintaining symphony 38 orchestras and receiving substantial support from vol- 39 untary contributions, none of the profits of which are 40 distributed to members of such organizations, or 41 exclusively to the benefit of persons in the military 42 or naval forces of the United States, or admissions to 43 agricultural fairs none of the profits of which are 44 distributed to stockholders or members of the asso- 45 elation conducting the same. 46 (c) The term "admission" as used in this title in- 47 "Admission" eludes seats and tables, reserved or otherwise, and 48 Defined other similar accommodations, and the charges made 49 therefor. 1 50 (d) The price (exclusive of the tax to be paid by 51 Price and the person paying for admission) at which every ad- 52 Other Details mission ticket or card is sold shall be conspicuously 53 to be and indelibly printed, stamped, or written on the face 54 Stamped on or back thereof, together with the name of the vendor 55 Tickets If sold other than at the ticket office of the theater, 56 opera, or other place of amusement. Whoever sells 57 an admission ticket or card on which the name of the 58 133 1 vendor and price Is not so printed, stamped, or written, 2 or at a price in excess of the price so printed, stamped, 8 or written thereon, is guilty of a misdemeanor, and 4 upon conviction thereof shall be fined not more than $100. 6 Club Dues 7 SECTION 801. That from and after April 1, 1919, 8 there shall be levied, assessed, collected, and paid, in 9 lieu of the taxes imposed by section 701 of the Rev- 10 enue Act of 1917, a tax equivalent to 10 per centum 11 of any amount paid on or after such date, for any 12 period after such date, (a) as dues or membership fees 13 (where the dues or fees of an active resident annual 14 member are in excess of $10 per year) to any social, 16 athletic, or sporting club or organization; or (b) as 16 initiation fees to such a club or organization, if such 17 fees amount to more than $10, or if the dues or mem- 18 bership fees 39 such products or merchandise without a bill, memoran- i 40 dum, or other evidence thereof as herein required, or 41 who delivers such bill, memorandum, or other evidence 42 of sale, or agreement to sell, without having the proper 43 st;nnp3 alfixed thereto, with intent to evade the fore- 44 going provisions, shall be deemed guilty of a misde- 45 meaner, and upon conviction thereof shall pay a fine 46 of not exceeding $1,000 or be imprisoned not more than 47 six months, or both. 48 No bill, memorandum, agreement, or other evidence 48 of such sale, or agreement of sale, or agreement to sell, 50 in case of cash sales of products or merchandise for 51 immediate or prompt delivery which in good faith are 52 actually intended to be delivered shall be subject to this 58 tax. Drafts, Checks 54 6. Drafts or checks (payable otherwise than at sight 55 or on demand) upon their acceptance or delivery within 56 the United States Avhichever is prior, promissory notes, 5T except bank notes issued for circulation, and for each 5f renewal of the same, for a sum not exceeding $100, 2 154 cents; and for each additional $100 or fractional part 1 thereof, 2 cents. 8 This subdivision shall not apply to a promissory note 3 secured by the pledge of bonds or obligations of the 4 United States issued after April 24, 1917, or secured by 6 the pledge of a promissory note which itself is secured 6 by the pledge of such bonds or obligations: Provided, 7 That in either case the par value of such bonds or 8 obligations shall be not less than the amount of such 9 note. 10 7. Conveyances: Deed, instrument, or writing, where- 11 Conveyances by any lands, tenements, or other realty sold shall be 12 granted, assigned, transferred, or otherwise conveyed 13 to, or vested in, the purchaser or purchasers, or any 14 other person or persons, by his, her, or their direction, 15 when the consideration or value of the interest or prop- 16 erty conveyed, exclusive of the value of any lien or 17 encumbrance remaining thereon at the time of sale, 18 exceeds ?100 and does not exceed $500, 50 cents; and 19 for each additional $500 or fractional part thereof, 50 20 cents. This subdivision shall not apply to any instru- 21 ment or writing given to secure a debt. 22 8. Entry of any goods, wares or merchandise at any 23 Entry of Goods custom house, either for consumption or warehousing, 24 not exceeding $100 in value, 25 cents; exceeding $100 25 and not exceeding $500 in value, 50 cents; exceeding 26 $500 in value, $1. 27 9. Entry for the withdrawal of any goods or mer- 28 chandise from customs bonded warehouse, 50 cents. 29 10. Passage ticket, one way or round trip, for each 30 Passage ticket passenger, sold or issued in the United States for pas- 31 sage by, any vessel to a port or place not in the United 32 States, Canada, or Mexico, if costing not exceeding $30,83 $1; costing more than $30 and not exceeding $60, $3; 34 costing more than $60, $5. This subdivision shall not 35 apply to passage tickets costing $10 or less. 36 11. Proxy for voting at any election for officers, or 37 Proxy meeting for the transaction of business, of any 38 corporation, except religious, educational, charitable, 39 fraternal, or literary societies, or public cemeteries, 40 10 cents. 41 12. Power of attorney granting authority to do or per- 42 Power of form some act for or in behalf of the grantor, which 43 Attorney authority is not otherwise vested in the grantee, 25 44 cents. This subdivision shall not apply to any papers 45 necessary to be used for the collection of claims from 46 the United States or from any State for pensions, 47 back pay, bounty, or for property lost in the military 48 or naval service, or to powers of attorney required in 49 bankruptcy cases. 61 13. Playing cards: Upon every pack of playing cards 50 Playing Cards containing not more than fifty-four cards, manufac- 52 tured or imported, and sold, or removed for consumption 53 or sale, a tax of 8 cents per pack. 54 14. Parcel-post packages: Upon every parcel or pack- 65 Parcel Post age transported from one point In the United States to 66 Packaf es another by parcel post on which the postage amounts 57 to 25 cents or more, a tax of 1 cent for each 25 cents 58 155 1 or fractional part thereof charged for such transporta- 2 tlon, to be paid by the consignor. 8 No such parcel or package shall be transported until 4 a stamp or stamps representing the tax due shall have 6 been affixed thereto. Insurance 6 15. On each policy of insurance, or certificate, binder, Policies, 7 covering note, memorandum, cablegram, letter, or other Binders, etc. 8 instrument by whatever name called whereby insur- 9 an<;e is made or renewed upon property within the 10 United States (including rents and profits) against peril 11 by sea or on inland waters or in transit on land (In- 12 eluding transshipments and storage at termini or way 13 points) or by fire, lightning, tornado, wind-storm, bom» 14 bardment, invasion, insurrection or riot, Issued to or for 16 or in the name of a domestic corporation or partnership 16 or an individual resident of the United States by any IT foreign corporation or partnership or any individual 18 not a resident of the United States, when such policy 19 or other instrument is not signed or countersigned by 20 an officer or agent of the insurer in a State, Territory, 21 or district of the United States within which such In- 22 surer is authorized to do business, a tax of 3 cents on 23 each dollar, or fractional part thereof of the premium 24 charged: Provided, That policies of re-insurance shall 25 be exempt from the tax imposed by this subdivision. aft Any person to or for whom or in whose name any 27 such policy or other instrument is issued, or any solici- 28 tor or broker acting for or on behalf of such person in 29 the procurement of any suca policy or other instru- aO ment, shal affix the proper stamps to such policy or 31 other instrument, and for failure to affix such stamps 32 with intent to evade the tax shall, in addition to other 33 penalties provided therefor, pay a fine of double the 34 amount of the tax. Child Labor 30 31' TITLE XII.— TAX ON EMPLOYMENT OF CHILD 88 LABOR. 39 40 SECTION 1200. That every person (other than a 41 bona fide boys* or girls' canning club recognized by the 42 Agricultural Department of a State and of the United 43 States) operating (a) any mine or quarry situated m 44 the United States in which children under the age of 45 sixteen years have been employed or permitted to work 46 during any portion of the taxable year; or (b) any 47 mill, cannery, workshop, factory, or manufacturing es- 48 tablishment situated in the United States in which chil- 49 dren under the age of fourteen years have been em- 50 ployed or permitted to work, or children between the 51 ages of fourteen and sixteen have been employed or 52 permitted to work more than eight hours in any day 53 or more than six days in any week, or after the hour 54 of seven o'clock post meridian, or before the hour of six 65 o'clock ante meridian, during any portion of the taxable 66 year, shall pay for each taxable year, in addition to all 67 other taxes imposed by law, an excise tax equivalent to 88 10 per centum of the entire net profits received or ac- 156 crued for such year from the sale or disposition of the 1 product of such mine, quarry, mill, cannery, workshop, 2 factory, or manufacturing establishment. 3 4 SECTION 1201. That in computing net profits under 5 Net Profits — the provisions of this title, for the purpose of the tax 6 How there shall be allowed as deductions from the gross 7 Computed amount received or accrued for the taxable year from 8 the sale or disposition of such products manufactured 9 within the United States the following items: 10 (a) The cost of raw materials entering into the pro- 11 duction ; 12 (b) Running expenses, including rentals, cost of re- 18 pairs, and maintenance, heat, power, insurance, man- 14 agement, and a reasonable allowance for salaries or 15 other compensations for personal services actually ren- 16 dered, and for depreciation; 17 (c) Interest paid within the taxable year on debts 18 or loans contracted to meet the needs of the business, 19 and the proceeds of which have been actually used to 20 meet such needs; 21 (d) Taxes of all kinds paid during the taxable year 22 with respect to the business or property relating to the 23 production; and 24 (e) Losses actually sustained within the taxable 25 year in connection with the business of producing 26 such products, including losses from fire, flood, storm, 27 or other casualties, and not compensated for by insur- 28 ance or otherwise. 29 30 SECTION 1202. That if any such person during any 31 Sales at Less taxable year or part thereof, whether under any agree- 32 Than Pair ment, arrangement, or understanding or otherwise, sells 33 Market Price or disposes of any product of such mine, quarry, mill, 34 cannery, workshop, factory, or manufacturing estab- 36 lishment at less than the fair market price obtainable 36 therefor either (a) in such manner as directly or indl- 37 rectly to benefit such person or any person directly or 38 indirectly interested in the business of such person; or 39 (b) with intent to cause such benefit; the gross amount 40 received or accrued for such year or part thereof from 41 the sale or disposition of such product shall be taken 42 to be the amount which would have been received or 48 accrued from the sale or disposition of such product if 44 sold at the fair market price. 45 46 SECTION 1203. (a) That no person subject to the 47 Exceptions provisions of this title shall be liable for the tax here- 48 in imposed if the only employment or permission to 49 work which but for this section would subject him to 60 the tax, has been of a child as to whom such person 51 has in good faith procured at the time of employing 62 such child or permitting him to work, and has since in 53 good faith relied upon and kept on file a certificate, 54 issued in such form, under such conditions and by such 55 persons as may be prescribed by a board consisting of 56 the Secretary, the Commissioner, and the Secretary of 57 Labor, showing the child to be of such age as not to 68 157 1 subject such person to the tax imposed by this title. 2 Any person who knowingly makes a false statement or 3 presents false evidence In or in relation to any such 4 certificate or application therefor shall be punished by B a fin© of not less than $100, nor more than $1,000, or 6 by imprisonment for not more than three months, or 7 by both such fine and imprisonment, in the discretion 8 of the court. 9 In any State designated by such board an employ- 10 ment certificate or other similar paper as to the age of 11 the child, issued under the laws of that State, and not 13 inconsistent with the provisions of this title, shall have 13 the same force and effect as a certificate herein pro- 14 vlded for. 15 (b) The tax imposed by this title shall not be im- 16 posed in the case of any person who proves to the satis- 17 faction of the Secretary that the only employment or 18 permission to work which but for this section would 19 subject him to the tax, has been of a child employed 20 or permitted to work under a mistake of fact as to the 21 age of such child, and without intention to evade the 22 tax. 23 Return of 24 SECTION 1204. That on or before the first day of Income 25 the third month following the close of each taxable 26 year, a true and accurate return under oath shall be 27 made by each person subject to the provisions of this 28 title to the collector for the district In which such per- 29 son has his principal ofEice or place of business, in such 30 form as the Commissioner, with the approval of the 31 Secretary, shall prescribe, setting forth specifically the 32 gross amount of income received or accrued during such 33 year from the sale or disposition of the product of any 34 mine, quarry, mill, cannery, workship, factory, or manu- 35 facturing establishment, in which children have been 36 employed subjecting him to the tax imposed by this 37 title, and from the total thereof deducting the aggre- 38 gate items of allowance authorized by this title, and 30 such other particulars as to the gross receipts and 40 items of allowance as the Commissioner, with the ap- 41 proval of the Secretary may require. 42 43 SECTION 1205. That all such returns shall be trans- 44 mitted forthwith by the collector to the Commissioner, 45 who shall, as soon as practicable, assess the tax founa 46 due and notify the person making such return of the 47 amount of the tax for which such person is liable, and 48 such person shall pay the tax to the collector on or 49 before thirty days from the date of such notice. 60 Commissioner 51 SECTION 1206. That for the purposes of this Act Has 62 the Commissioner, or any other person duly authorized Authority to 53 by him, shall have authority to enter and inspect at Inspect 54 any time any mine, quarry, mill, cannery, workshop, Premises 55 factory, or manufacturing establishment. The Secre- 66 tary of Labor, or any person duly authorized by him, 67 shall, for the purpose of complying with a request of 08 the Commissioner to make such an inspection, have like 158 authority, and shall make report to the Commissioner 1 of inspections made under such authority in such form 2 as may be prescribed by the Commissioner with the 3 approval of the Secretary of the Treasury, 4 Any person who refuses or obstructs entry or inspec- 6 tion authorized by this section shall be punished by a 6 fine of not more than $1,000, or by imprisonment for 7 not more than one year, or both such fine and imprison- 8 ment. 9 10 SECTION 1207. That as used in this title the term 11 "taxable year" shall have the same meaning as pro- 12 vided for the purposes of income tax in section 200. 13 The first taxable year for the purposes of this title 14 shall be tTie period between sixty days after the pas- 15 sage of this Act and December 31, 1919, both inclusive, 16 or such portion of such period as is included within 17 the fiscal year (as defined in section 200) of the tax- 18 payer. 19 80 TITLE XIII.— GENERAL ADMINISTRATIVE 22 PROVISIONS. 23 24 SECTION 1300. That hereafter the salary of the 25 Salary of Commissioner shall be $10,000 a year. The difference 26 Commissioner between the amount appropriated under existing law 27 and the salary herein established shall, for the period 28 between the passage of this Act and July 1, 1919, be 29 paid out of the appropriations for collecting internal 30 revenue. 31 32 SECTION 1301. (a) That hereafter there may be 33 DfM)Uty employed in the Bureau of Internal Revenue, in lieu 34 Commissioner of the deputy commis.sioners who.se salaries are now 35 fixed by law, five deputy commissioners and an assistant 36 to the Commissioner, who shall each receive a salary 37 of $5,000 a year, payable monthly. The assistant to 38 the Commissioner may be authorized by the Commis- 39 sioner to perform any duties which the deputy com- 40 missioners may perform under existing law. 41 (b) The salaries of collectors may be readjusted and 42 Increased under such regulations as may be prescribed 43 by the Commissioner, subject to the approval of the 44 Secretary, but no collector shall receive a salary in 45 excess of $6,000 a year. 46 (c) There is hereby appropriated, out of any money 47 Appropriation in the Treasury not otherwise appropriated, for the 48 for fiscal year ending June 30, 1919, the sum of $7,500,000 49 Assessment for the expenses of assessing and collecting the inter- 50 and nal-revenue taxes as provided in this Act, including the 61 Collection employment of necessary officers, attorneys, experts, 52 agents, inspectors, deputy collectors, clerks, janitors, 53 and messengers, in the District of Columbia and the 54 several collection districts, to be appointed as provided 55 by law, telegraph and telephone service, rental and re- 56 pair of quarters, postage, and the purchase of such sup- 57 plies, equipment, furniture, mechanical devices, print- 58 159 Advisory- Tax Board I Ing, stationery, law books and books of reference, not a to exceed $500 for street car fares in tlie District of 3\:olumbia, and sucli other articles as may be necessary 4''for use in the District of Columbia and the several col- 5! lection districts: Provided, That not more than $2,750,- ejooo of the total amount appropriated by this section may be expended in the Bureau of Internal Revenue, in the District of Columbia. (d) (1) There is hereby created a board to be known __ as the "Advisory Tax Board," hereinafter called the llJBoard, and to be composed of not to exceed six mem- 12 bers to be appointed by the Commissioner with the ap- 13 proval of the Secretary. The Board shall cease to exist 14 at the expiration of two years after the passage of this 15 Act, or at such earlier time as the Commissioner with leithe approval of the Secretary may designate. Vacancies in the membership of the Board shall be 18 filled in the same manner as an original appointment. 19 Any member shall be subject to removal by the Com- 20 missioner with the approval of the Secretary. The 21 22 Commissioner with the approval of the Secretary shall designate the chairman of the Board. Each member shall receive an annual salary of $9,000, payable 24l monthly, together with actual necessary expenses when 26 absent from the District of Columbia on official busi- 26 ness. Interpretation 27;! (2) The Commissioner may, and on the request of of Tax Act 28 any taxpayer directly interested shall, submit to the 29 Board any question relating to the interpretation or 30 administration of the income, war-proflts or excess- 31 profits tax laws, and the Board shall report its findings 32 and recommendations to the Commissioner. 33 (3) The Board shall have its office in the Bureau o' 34 Internal Revenue in the District of Columbia. The ex 36 penses and salaries of members of the Board shall be 86 audited, allowed, and paid out of appropriations for 87 collecting internal revenue, in the same manner as ex- 88 penses and salaries of employees of the Bureau of 39 Internal Revenue are audited, allowed, and paid. Broad Powers 40 (4) The Board shall have the power to summon wit- of Board 41 nesses, take testimony, administer oaths and to require 48 imy person to produce books, papers, documents or other 43 data relating to any matter under investigation by the 44 Board. Any member of the Board may sign subpoenas 46 and members and employees of the Bureau of Internal 46 Revenue designated to assist the Board, when author- 47 Ized by the Board, may administer oaths, examine wlt- 48 nesses, take testimony and receive evidence. 48 Leave of 50 SECTION 1302. That all Internal-revenue agents Absence for 61 and inspectors shall be granted leave of absence with Aarents 52 pay, which shall not be cumulative, not to exceed thirty 63 days in any calendar year, under such regulations as 64 the Commissioner, with the approval of the Secretary, 65 may prescribe. Legislative 66 Drafting 57 SECTION 1303. (a) That there is hereby created a Service 58 Legislative Drafting Service under the direction of two 160 draftsmen, one of whom shall be appointed by the Presl- 1 dent of the Senate, and one by the Speaker of the House 2 of Representatives, without reference to political afCilia- 3 tions and solely on the ground of fitness to perform 4 the duties of the office. Each draftsman shall receive 6 a salary of $5,000 a year, payable monthly. The drafts- 6 men shall, subject to the approval of the President of 7 - the Senate and the Speaker of the House of Repre- 8 sentatives, employ and fix the compensation of such 9 assistant draftsmen, clerks, and other employees, and 10 purchase such furniture, office equipment, books, sta- 11 tionery, and other supplies, as may be necessary for 12 the proper performance of the duties of the service 13 and as may be appropriated for by Congress. 14 (b) The Drafting Service shall aid in drafting public 16 bills and resolutions or amendments thereto on the 16 rquest of any committee of either House of Congress, 17 but the Library Committee of the Senate and the Lib- 18 rary Committee of the House of Representatives, re- 19 spectively, may determine the preference, if any, to be 20 given to such requests of the committees of either 21 House, respectively. The draftsmen shall, from time 22 to time, prescribe rules and regulations for the conduct 23 of the work of the service for the committees of each 24 House, subject to the approval of the Library Commit- 25 tee of each House, respectively. 26 (c) For the remainder of the current fiscal year there 27 is hereby appropriated, out of any money in the Treas- 28 ury not otherwise appropriated, the sum of $25,000, or 29 so much thereof as may be necessary, for the purpose 30 of defraying the expenses of the establishment and 31 maintenan'ce of the service, including the payment of 32 salaries herein authorized. One-half of all appropria- 33 tions for the service shall be disbursed by the Secretary 34 of the Senate and one-half by the Clerk of the House 36 of Representatives. 86 37 SECTION 1304. That there shall be levied, collected, 38 Tax on and paid in the United States, upon articles coming into 39 Importation the United States from the Virgin Islands, a tax equal 40 of Articles to the internal-revenue tax imposed in the United States 41 from Virgin upon like articles of domestic manufacture; such ar- 42 Islands tides shipped from such islands to the United States 43 shall be exempt from the payment of any tax imposea 44 by the internal-revenue laws of such islands: Provided, 45 That there shall be levied, collected, and paid In such 46 islands, upon articles imported from the United States, 47 a tax equal to the internal-revenue tax imposed in such 48 islands upon like articles there manufactured; and such 49 articles going into such islands from the United States 50 shall be exempt from payment of any tax imposed by 51 the internal-revenue laws of the United States. 52 53 SECTION 1305. That all administrative, special, or 54 stamp provisions of law, including the law relating to 55 the assessment of taxes, so far as applicable, are here- 56 by extended to and made a part of this Act, and every 67 person liable to any tax imposed by this Act, or for 58 161 1 the collection thereof, shall keep such records and ren- 2der, under oath, such statements and returns, and shall 8 comply with such regulations as the Commissioner, 4 with the approval of the Secretary, may from time to 6 time prescribe, rowers of 6 Whenever in the judgment of the Commissioner nec- Commi»«ioner 7 essary he may require any person, by notice served upon 8 him, to make a return or such statements as he deems 9 sufficient to show whether or not such person is liable 10 to tax. 11 The Commissioner, for the purpose of ascertaining 18 the correctness of any return or for the purpose of 13 making a return where none has been made, is hereby 14 authorized, by any revenue agent or inspector desig- IB nated by him for that purpose, to examine any books, 16 papers, records or memoranda bearing upon the mat- 17 ters required to be included in the return, and may 18 require the attendance of the person rendering the re- 19 tui^n or of any officer or employee of such person, or 20 the attendance of any other person having knowledge 21 in the premises, and make take his testimony with 22 reference to the matter required by law to be included 23 in such return, with power to administer oaths to such 24 person or persons. Floor Taxes — 26 SECTION 1306, That where floor taxes are imposed Return Under 27 by this Act in respect to articles or commodities, in Oath 28 respect to which the tax imposed by existing law haa 29 been paid, the person required by this Act to pay the 30 tax shall, within thirty days after its passage, make 31 return under oath in such form and under such regula- 32 tions as the Commissioner, with the approval of the 33 Secretary, shall prescribe. Payment of the tax shown 34 to be due may be extended to a date not exceeding seven 35 months from the passage of this Act, upon the filing of 36 a bond for payment in such form and amount and with 37 such sureties as the Commissioner, with the approval 38 of the Secretary, may prescribe. 40 SECTION 1307. That in all cases where the method 41 of collecting the tax imposed by this Act is not specifl- 42 cally provided in this Act, the tax shall be collected In 43 such manner as the Commissioner, with the approval of 44 the Secretary, may prescribe. All administrative and 45 penalty provisions of Title XI of this Act, in so far as 46 applicable, shall apply to the collection of any tax 47 which the Commissioner determines or prescribes shall 48 be paid by stamp. 49 Penalties 60 SECTION 1308. (a) That any person required under 61 Titles V, VI, VII, VIII, IX, X, or XII, to pay, or to 52 collect, account for and pay over any tax, or required by 63 law or regulations made under authority thereof to 54 make a return or supply any information for the pur- 55 pcses of the computation, assessment or collection of 56 any such tax, who fails to pay, collect, or truly account 57 for and pay over any such tax, make any such return 58 or supply any such information at the time or times 162 required by law or regulation shall in addition to other 1 penalties provided by law be subject to a penalty of not S more than $1,000. ., 8 (b) Any person who willfully refuses to pay, collect, 4 or truly account for and pay over any such tax, make • such return or supply such information at the time or 6 times required by law or regulation, or who willfully 7 attempts in any manner to evade such tax shall be 8 guilty of a misdemeanor and in addition to other penal- 9 ties provided by law shall be fined not more than 10 $10,000 or imprisoned for not more than one year, or 11 both, together with the costs of prosecution. 12 (c) Any person who willfully refuses to pay, collect 13 or truly account for and pay over any such tax shall in 14 addition to other penalties provided by law be liable 15 to a penalty of the amount of the tax evaded, or not 16 paid, collected, or accounted for and paid over, to be 17 assessed and collected in the same manner as taxes are 18 assessed and collected: Provided, however. That no pen- 19 alty shall be assessed under this subdivision for any 20 offense for which a penalty may be assessed under au- 81 thority of section 3176 of the Revised Statutes, as 22 amended, or of section 605 or 620 of this Act, or for 23 any offense for which a penalty has been recovered 24 under section 3256 of the Revised Statutes. 25 (d) The term "person" as used in this section in- 26 eludes an ofRcer or employee of a corporation or a 27 member or employee of a partnership, who as such off i- 28 cer, employee, or member is under a duty to perform 29 the act in respect of which the violation occurs. 30 31 SECTION 1309. That the Commissioner, with the 38 approval of the Secretary, is hereby authorized to make 33 all needful rules and regulations for the enforcement 34 of the provisions of this Act. 36 The Commissioner with such approval may by regula-36 tion, provide that any return required by Titles V, VI, 37 VII, VIII, IX or X to be under oath may, if the 38 amount of the tax covered thereby is not in excess of 39 $10, be signed or acknowledged before two witnesses 40 Instead of under oath. 41 42 SECTION 1310. (a) That in the case of any over- 43 Over-payment payment or overcollection of any tax imposed by sec- 44 of Tax tion 628 or 630 or by Title V, Title VIII, or Title IX, 46 the person making such overpayment or overcollection 46 may take credit therefor against taxes due upon any 47 monthly return, and shall make refund of any excessiv©48 amount collected by him upon proper application by 49 the person entitled thereto. 60 (b) Wherever in this Act a tax is required to be 51 Payment of paid by the purchaser to the vendor at the time of a 62 Tax by sale, and such sale is made on credit, then, under regu- 63 Vendor lations prescribed by the Commissioner, with the ap- 64 proval of the Secretary, the tax may, at the option of 66 the vendor, be returned and paid by him to the United 66 States as if paid to him by the purchaser at the time 67 of the sale, and In such case the vendor shall have 68 163 1 a right of action In any court of competent jurUdlc- 2 tion against the purchaser for the amount of the tax 3 so returned and paid to the United States. Tax on Articles 4 (c) Under such rules and regulations as the Com- for Export 5 missloner with the appi'oval of the Secretary may pre- Except when 6 scribe, the taxes Imposed under the provisions of Titles Approved by 7 VI, VII or IX shall not apply in respect to articles sold Secretary 8 or leased for export and in due course so exported. 8 Under such rules and regulations the amount of any 10 internal-revenue tax erroneously or illegally collected 11 in respect to exported articles may be refunded to the 12 exporter of the article, instead of to the manufacturer, 13 if the manufacturer waives any claim for the amount 14 so to be refunded. 15 Old Stamps 16 SECTION 1311. That where the rate of tax imposed May Be 17 by this Act, payable by stamps, is an increase over Used — ^When 18 previously existing rates, stamps on hand in the col- 19 lectors' offices and in the Bureau of Internal Revenue 20 may continue to be used until the supply on hand is 21 exhausted, but shall be sold and accounted for at the 22 rates provided by this Act, and assessment shall be 23 made against manufacturers and other taxpayers hav- 24 ing such stamps on hand on the day this Act takes 25 effect for the difference between the amount paid for 26 such stamps and the tax due at the rates provided by 27 this Act. 28 Bona-fide 29 SECTION 1312. (1) That (a) if any person has prior Contracts 30 to May 9, 1917, made a bona fide contract with a dealer Made Before 31 for the sale or lease, after the tax takes effect, of any Passage of 32 article In respect to which a tax is imposed under Title Act 33 VI, VII, or IX, or under subdivision 13 of Schedule A 34 of Title XI, or under this subdivision, and (b) if such 35 contract does not permit the adding of the whole of 36 such tax to the amount to be paid under such contract, 37 then the vendee or lessee shall, in lieu of the vendor 38 or lessor, pay so much of such tax as is not so per- 39 mltted to be added to the contract price. If a contract 40 of the character above described was made with any 41 person other than a dealer, the tax collected under this 42 Act shall be the tax in force on May 9, 1917. 43 (2) If (a) any person has prior to September 3, 1918, 44 made a bona fide contract with a dealer for the sale 43 or lease, after the tax takes effect, of any article in 46 respect to which a tax is imposed under Title VI, VII, 47 or IX, or under subdivision 13 of Schedule A of Title 48 XI, or under this subdivision, and in respect to which 49 no corresponding tax was imposed by the Revenue Act 50 of 1917, and (b) such contract does not permit the 61 adding, to the amount to be paid under such contract, 62 of the whole of the tax Imposed by this Act, then the 53 vendee or lessee shall, in lieu of the vendor or lessor, 54 pay so much of the tax Imposed by this Act as is not 55 so permitted to be added to the contract price. If a 56 contract of the character above described was made 57 with any person other than a dealer, no tax shall be B9 collected under this Act. 164 (3) If (a) any person has prior to September 3, 1918, 1 made a bona fide contract with a dealer for the sale 2 or lease, after the tax takes effect, of any article in 3 respect to which a tax Is imposed und.er Title VI, VII, 4 or IX, or under subdivision 13 of Schedule A of Title 5 XI, or under this subdivision, and in respect to which a 6 corresponding tax was imposed by the Revenue Act of 7 1917, and (b) such contract does not permit the add- 8 ing-, to the amount to be paid under such contract, of 9 the whole of the difference between such tax and tne 10 corresponding tax imposed by the Revenue Act of 1917, 11 then the vendee or lessee shall, in lieu of the vendor 12 or lessor, pay so much of such difference as is not so 13 permitted to be added to the contract price. If a con- 14 tract of the character above described was made with 15 any person other than a dealer, the tax collected under 16 this Act shall be the tax in force on September 3, 1918. 17 (4) The taxes payable by the vendee or lessee under 18 this section shall be paid to the vendor or lessor at the 19 time the sale or lease is consummated, and collected, re- 20 turned, and paid to the United States by such vendor or 21 lessor in the same manner as provided in section 502. 22 (5) The term "dealer" as used in this section in- 23 eludes a vendee who purchases any article with intent 24 to use it in the manufacture or production of another 25 article intended for sale. 26 (6) This section shall not apply to any tax imposed 27 by section 906. 28 29 SECTION 1313. That in the payment of any tax un-30 Fractional der this Act not payable by stamp a fractional part of 31 Parts of a a cent shall be disregarded unless it amounts to one- 32 a Cent half cent or more, in which case it shall be increased to 33 1 cent. 34 35 SECTION 1314. That collectors may receive, at par 36 Payment by with an adjustment for accrued interest, certificates of 37 Uncertified indebtedness issued by the United States and uncerti- 38 Check or fled checks in payment of income, war-profits and 39 with U. S. excess-profits taxes and any other taxes payable other 40 Ctfs. of than by stamp, during such time and under such regu-41 Indebtedness lations as the Commissioner, with the approval of the 42 Secretary, shall prescribe; but if a check so received 43 Is not paid by the bank on which it is drawn the per- 44 son by whom such check has been tendered shall re- 45 main liable for the payment of the tax and for all legal 46 penalties and additions the same as if such check had 47 not been tendered. 48 49 SECTION 1315. That section 3315 of the Revised 50 Statutes, as amended, is hereby amended to read af» 51 follows: 52 53 "Section 3315. The Commissioner of Internal Rev- 54 enue may, under regulations prescribed by him with 55 the approval of the Secretary of the Treasury, issue 56 stamps for restamping packages of distilled spirits. 57 tobacco, cigars, snuff, cigarettes, fermented liquors, and 58 165 X wines which have been duly stamped but from which 2 the stamps have been lost or destroyed by unavoid- 3 able accident." 4 5 SECTION 1316. (a) That section 3220 of the Re- • vised Statutes is hereby amended to read as follows: 7 8 "Section 3220. The Commissioner of Internal Rev- • enue, subject to regulations prescribed by the Secretary 10 of the Treasury, is authorized to remit, refund, and pay 11 back all taxes erroneously or illegally assessed or col- 12 lected, all penalties collected without authority, and all 18 taxes that appear to be unjustly assessed or excessive 14 in amount, or in any manner wrongfully collected; also 15 to repay to any collector or deputy collector the full 16 amount of such sums of money as may be recovered 17 against him in any court, for any internal revenue taxes 18 collected by him, with the cost and expenses of suit; 18 also all damages and costs recovered against any asses- 20 sor, assistant assessor, collector, deputy collector, ISA agent, or inspector, in any suit brought against him by 22 reason of anything done in the due performance of his 23 official duty, and shall make report to Congress at the 24 beginning of each regular session of Congress of all 26 transactions under this section," 26 27 (b) Section 3225 of the Revised Statutes of the 28 United States is hereby amended to read as follows: 28 80 "Section 3225. When a second assessment is made 31 in case of any list, statement, or return, which in the 38 opinion of the collector or deputy collector was false 38 or fraudulent, or contained any understatement or un- 84 dervaluation, such assessment shall not be remitted, 85 nor shall taxes collected under such assessment be re- 36 funded, or paid back, or recovered by any suit, unless it 37 is proved that such list, statement, or return was not 38 willfully false or fraudulent and did not contain any 39 willful understatement or undervaluation." 40 41 (c) That the paragraph of section 3689 of the Re- 48 vised Statutes, as amended, reading as follows: 43 "Refunding taxes illegally collected (internal rev- 44 enue) : To refund and pay back duties erroneously or 46 illegally assessed or collected under the internal-rev- 46 enue laws," is repealed from and after June 30, 1920; 47 and the Secretary of the Treasury shall submit for the 48 fiscal year 1921, and annually thereafter, an estimate of 48 appropriations to refund and pay back duties or taxes 60 erroneously or illegally assessed or collected under the 51 internal-revenue laws, and to pay judgments, including 68 interest and costs, rendered for taxes or penalties er- 63 roneously or illegally assessed or collected under the 54 internal-revenue laws. •6 •6 SECTION 1317. That section* 3164, 3165. 3167, 3172. 57 8173. and 3176 of the Revised Statutes as amended are 68 hereby amended to read as follows: 166 "Section 3164. It shall be the duty of every col- 1 lector of internal x-evenue having knowledge of any will- 2 ful violation of any law of the United States relating 3 to the revenue, within thirty days after coming into 4 possession of such knowledge, to file with the district 6 attorney of the district in which any fine, penalty, or 6 forfeiture may be incurred, a statement of all the facts 7 and circumstances of the case within his knowledge, 8 together with the names of the witnesses, setting forth 9 the provisions of law believed to be so violated on 10 which reliance may be had for condemnation or con- 11 viction. IS "Section 3165. Every collector, deputy collector, 13 internal-revenue agent, and internal-revenue officer as- 14 signed to duty under an internal-revenue agent, % au- 16 thorized to administer oaths and to take evidence 16 touching any part of the administration of the internal- 17 revenue laws with which he is chai-ged, or where such 18 oaths and evidence are authorized by law or regula- 19 tion authorized by law to be taken. SO 81 •'Section 3167. It shall be unlawful for any col- 22 Secrecy of lector, deputy collector, agent, clerk, or other officer or 23 Information employee of the United States to divulge or to make 24 Obtained by known in any manner whatever not provided by law to 25 Collectors any person the operations, style of work, or apparatus 26 of any manufacturer or producer visited by him in the 27 discharge of his official duties, or the amount or source 28 of income, profits, losses, expenditures, or any partic- S9 ular thereof, set forth or disclosed in any income re- 30 turn, or to permit any income return or copy thereof 31 or any book containing any abstract or particulars 38 thereof to be seen or examined by any person except 33 as provided by law; and it shall be unlawful for any 34 person to print or publish in any manner whatever not 35 provided by law any income return, or any part thereof 36 or source of income, profits, losses, or expenditures ap- 37 pearing in any income return; and any offense against 38 the foregoing provision shall be a misdemeanor and 39 be punished by a fine not exceeding $1,000 or by im-40 prisonment not exceeding one year, or both, at the dis- 41 cretion of the court; and if the offender be an officer 42 or employee of the United States he shall be dismissed 43 from office or discharged from employment. 44 45 "Section 3172. Every collector shall, from time to;46 Canvass of time, cause his deputies to pi-oceed through every part 47 Collection of his district and inquire after and concerning all 48 District persons therein who are liable to pay any internal revenue tax, and all persons owning or having the care||50 and management of any objects liable to pay any tax and to make a list of such persons and enumerate said objects. Bl 52 63 |64 55 56 "Section 3173. It shall be the duty of any person, partnership, firm, association, or corporation, made liable to any duty, specal tax, or other tax Imposed by|57 law, when not otherwise provided for, (1) in case of a{|58 List Return by Person, Corporation, Partnership X67 1 special tax, on or before the thirty-first day of July in 2 each year, and (2) In other cases before the day on 3 which the taxes accrue, to make a list or return, veri- 4 fled by oath, to the collector or a deputy collector of 6 the district where located, of the articles or objects, in- 6 eluding the quantity of goods, wares, and merchandise, ^made or sold and charged with a tax, the several rates 8 and aggregate amount, according to the forms and 9 regulations to be prescribed by the Commissioner of In- 10 ternal Revenue, with the approval of the Secretary of 11 ihe Treasury, for which such person, partnership, firm, 12 association, or corporation is liable: Provided, That If 13 any person liable to pay any duty or tax, or owning, 14 possessing, or having the care or management of prop- 15 erty, goods, wares, and merchandise, article or objects IS liable to pay any duty, tax, or license, shall fail to 17 make and exhibit a list or return required by law, but 18 shall consent to disclose the particulars of any and 19 all the property, goods, wares, and merchandise, ar- 20 tides, and objects liable to pay any duty or tax, oi 21 any business or occupation liable to pay any tax as 22 aforesaid, then, and in that case, it shall be the duty 23 of the collector or deputy collector to make such list or 24 return, which, being distinctly read, consented to, and 25 signed and verified by oath by the person so owning, 26 possessing, or having the care and management as 27 aforesaid, may be received as the list of such person: 28 Provided further. That In case no annual list or return 29 has been rendered by such person to the collector or 30 deputy collector as required by law, and the person 31 shall be absent from his or her residence or place of 33 business at the time the collector or a deputy collector 3^ shall call for the annual list or return, it shall be the 34 duty of such collector or deputy collector to leave at 36 such place of residence or business, with some one of 36 suitable age and discretion, if such be present, other- 87 wise to deposit in the nearest post office, a note or 38 memorandum addressed to such person, requiring him 39 or her to render to such collector or deputy collector the 40 list or return required by law within ten days from the 41 date of such note or memorandum, verified by oath. 42 And if any person, on being notified or required as 43 aforesaid, shall refuse or neglect to render such list or 4^ return within the time required as aforesaid, or when- 4S*-ever any person who is required to deliver a monthly 46 or other return of objects subject to tax fails to do so 47 at the time required, or delivers any return which, in 48 the opinion of the collector, is erroneous, false, or 49 fraudulent, or contains any undervaluation or under- 50 statement, or refuses to allow any regularly author- 51 ized Government officer to examine the books of such 52 person, firm, or corporation, it shall be lawful for 63 the collector to summon such person, or any other 54 person having possession, custody, or care of books Sn of account containing entries relating to the business 80 of such person or any other person he may deem 57 proper, to appear before him and produce such books 68 at a time and place named in the summons, and to 1G8 give testimony or answer interrogatories, under oath, 1 respecting- any objects or income liable to tax or the 2 returns thereof. The collector may summon any per- 3 son residing or found within the State or Territory 4 In which his district lies; and when the person in- 5 tended to be summoned does not reside and can not 6 be found within such State or Territory, he may enter 7 any collection district where such person may be found 8 and there make the examination herein authorized. 9 And to this end he may there exercise all the authority 10 which he might lawfully exercise in the district for 11 which he was commissioned: Provided, That 'person,' 12 as used in this section, shall be construed to include 13 any corporation, joint-stock company or association, 14 or insurance company when such construction is neces- IS sary to carry out its provisions. 16 "Section 3176. If any person, corporation, company, 17 Penalty or association fails to make and file a return or list 18 Failure to at the time prescribed by law or by regulation made 19 File Return under authority of law, or makes, willfully or other- 20 wise, a false or fraudulent return or list, the col- 21 lector or deputy collector shall make the return or 22 list from his own knowledge and from such informa- 23 tion as he can obtain through testimony or otherwise. 24 In any such case the Commissioner may, from his 25 own knowledge and from such information as he can 26 obtain through testimony or otherwise, make a return 27 or amend any return made by a collector or deputy 28 collector. Any return or list so made and subscribed 29 by the Commissioner, or by a collector or deputy col- 30 lector and approved by the Commissioner, shall be 31 prima facie good and sufficient for all legal purposes. 32 "If the failure to file a return or list is due to 33 sickness or absence, the collector may allow such 34 further time, not exceeding thirty days, for making 35 and filing the return or list as he deems proper. 36 "The Commissioner of Internal Revenue shall de- 37 termine and assess all taxes, other than stamp taxes, 38 as to which returns or lists are so made under tn« 89 provisions of this section. In case of any failure to 40 make and file a return or list within the time pre- 41 scribed by law, or prescribed by the Commissioner of 42 Internal Revenue or the collector in pursuance of law, 43 the Commissioner of Internal Revenue shall add to 44 the tax 25 per centum of its amount, except that 45 when a return is filed after such time and it is shown 46 that the failure to file it was due to a reasonable cause 47 and not to willful neglect, no such addition shall be 48 made to the tax. In case a false or fraudulent re- 49 turn or list is willfully made, the Commissioner of 50 Internal Revenue shall add to the tax 50 per centum 81 of its amount. 52 "The amount so added to any tax shall be collected 53 at the same time and in the same manner and as part 64 of the tax unless the tax has been paid before the 55 discovery of the neglect, falsity, or fraud, in which 56 case the amount so added shall be collected in the 57 same manner as the tax." 68 169 Summons 1 SECTION 1318. That if any person is summoned Jurisdiction 2 under this Act to appear, to testify, or to produce 3 books, papers or other data, the district court of the 4 United States for the district in which such person 6 resides shall have jurisdiction by appropriate process 6 to compel such attendance, testimony, or production of 7 books, papers, or other data. 8 The district courts of the United States at the in- 9 stance of the United States are hereby invested with 10 such jurisdiction to make and issue, both in actions at 11 law and suits in equity, writs and orders of injunction, 12 and of ne exeat republica, orders appointing receivers, 13 and such other orders and process, and to render such 14 judgments and decrees, granting in proper cases both 15 legal and equitable relief together, as may be necessary 16 or appropriate for the enforcement of the provisions of 17 this Act. The remedies hereby provided are in addi- 18 tion to and not exclusive of any and all other remedies 19 of the United States in such courts or otherwise to en- 20 force such provisions. 21 False 22 SECTION 1319. That whoever in connection with Statements — 23 the sale or lease, or offer for sale or lease, of any Penalties 24 article, or for the purpose of making such sale or 26 lease, makes any statement, written or oral, (1) in- 26 tended or calculated to lead any person to believe that 27 any part of the price at which such article is sold or 28 leased, or offered for sale or lease, consists of a tax 29 imposed under the authority of the United States, or 30 (2) ascribing a particular part of such price to a tax 31 imposed under the authority of the United States, 32 knowing that such statement is false or that the tax 33 Is not so great as the portion of such price ascribed 34 to such tax, shall be guilty of a misdemeanor and upon 35^conviction thereof shall be punished by a fine of not 36 more than $1,000 or by imprisonment not exceeding one 37Vear, or both. Sureties 39 SECTION 1320. That wherever by the laws of th« Required 40 United States or regulations made pursuant thereto, 41 nny person is required to furnish any recognisance, 42 Stipulation, bond, guarantee, or undertaking, hereinafter 48 called "penal bond," with surety or sureties, such 44 'person may, in lieu of such surety or sureties, deposit 45ias .security with the official having authority to ap- 46 prove such penal bond. United States Liberty bonds 47 or other bonds of the United States in a sum equal 48 at their par value to the amount of such penal bond 49 required to be furnished, together with an agreement 80, authorizing such official to collect or sell such bonds 51 so deposited in case of any default in the perform- 82 fince of any of the conditions or stipulations of such 53, penal bond. The acceptance of such United States 64 bonds in lieu of surety or sureties required by law 66 shall have the same force and effect as individual or 66 corporate suretie.s, or certified checks, bank drafts, 67 post-office money orders, or cash, for the penalty or 68 amount of such penal bond. The bonds deposited 170 hereunder, and such other United States bonds as may 1 be substituted therefor from time to time as such 2 security, may be deposited with the Treasurer, or an 8 Assistant Treasurer of the United States, a Govern- 4 ment depository. Federal Reserve bank, or member 5 bank, which shall issue receipt therefor, describing- • such bonds so deposited. As soon as security for 7 the performance of such penal bond is no longer nee- 8 essary, such bonds so deposited, shall be returned to 9 the depositor: Provided, That in case a person or 10 persons supplying a contractor with labor or material 11 as provided by the Act of Congress, approved Feb- IS ruary 24, 1905 (33 Stat, 811), entitled "An Act to 13 amend an Act approved August thirteenth, eighteen 14 hundred and ninety-four, entitled 'An Act for the 15 protection of persons furnishing materials and labor 16 for the construction of public works,' " shall file with 17 the obligee, at any time after a default in the per- 18 formance of any contract subject to said Acts, the ap- 19 plication and affidavit therein provided, the obligee 20 shall not deliver to the obligor the deposited bonds 21 nor any surplus proceeds thereof until the expiration 22 of the time limited by said Acts for the institution 23 of suit by such person or persons, and, in case suit 24 shall be instituted within such time, shall hold said 26 bonds or proceeds subject to the order of the court 26 having jurisdiction thereof: Provided further. That 27 nothing herein contained shall affect or impair the 28 priority of the claim of the United States against the 29 bonds deposited or any right or remedy granted by 30 said Acts or by this section to the United States for 31 default upon any obligation of said penal bond: Pro- 32 vided further. That all laws inconsistent with this 33 section are hereby so modified as to conform to the 34 provisions hereof: And provided further, That nothing 35 contained herein shall affect the authority of courts 36 over the security, where such bonds are taken as 37 security in judicial proceedings, or the authority of 38 any administrative officer of the United States to 39 receive United States bonds for security in cases au-40 thorized by existing laws. The Secretary may prescribe 41 rules and regulations necessary and proper for carry- 42 Ing this section into effect. 48 44 45 TITLE XIV.— GENERAL PROVISIONS. 46 47 SECTION 1400. (a) That the following parts of 48 Acts are hereby repealed, subject to the limitations 49 provided in subdivision (b): 60 (1) The following titles of the Revenue Act of 1916:61 Title I (called "Income Tax"); 62 Title II (called "Estate Tax"); 63 Title III (called "Munitions Manufacturers' Tax"), 64 as amended; 56 Title IV (called "Miscellaneous Taxes"). 66 (2) The following parts of the Act entitled "An Act 67 to provide increased revenue to defray the expenses 68 171 1 of the Increased appropriations for the Army and Navy 2 and the extensions of fortifications, and for other pur- 3 poses," approved March 3, 1917: 4 Title III (called "Estate Tax"); 6 Section 402 (called "Returns of Dividends"). 6 (3) The following titles of the Revenue Act of 1917: 7 Title I (called "War Income Tax"); 8 Title II (called "War Excess-Profits Tax"); 9 Title III (called "War Tax on Beverages"); 10 Title IV (called "War Tax on Cigars, Tobacco, and 11 Manufactures Thereof"); 12 Title V (called "War Tax on Facilities Furnished by 13 TMiblic Utilities, and Insurance"); 14 Title VI (called "War Excise Taxes"); 15 Title VII (called "War Tax on Admissions and 16 Ones"); 17 Title VIII (called "War Stamp Taxes"); 18 Title IX (called "War Estate Tax"); 19 Title X (called "Administrative Provisions"); 20 Title XII (called "Income-Tax Amendments"). 21 (b) Such parts of Acts shall remain in force for 22 tlie assessment and collection of all taxes which have 23 accrued thereunder, and for the imposition and col- 24 lection of all penalties or forfeitures which have ac- 25 ciued and may accrue in relation to any such taxes, 26 and except that the unexpended balance of any ap- 27 propriation heretofore made and now available for 28 the administration of any such part of an Act shall 29 be available for the administration of this Act or the 30 corresponding provision thereof: Provided, That, ex- 31 cept as otherwise provided in this Act, no taxes shall 32 be collected under Title I of the Revenue Act of 1916 33 as amended by the Revenue Act of 1917, or Title I or 34 II of the Revenue Act of 1917, in respect to any period 35 after December 31, 1917: Provided further, That the 36 assessment and collection of all estate taxes, and the 37 imposition and collection of all penalties or forfeitures, 38 which have accrued under Title II of the Revenue 39 Act of 1916 as amended by the Act entitled "An Act 40 to provide increased revenue to defray the expenses 41 of the increased appropriations for the Army and Navy 42 and the extensions of fortifications, and for other 43 purposes," approved March 3, 1917, or Title IX of the 44 Revenue Act ol 1917, shall be according to the provl- 45 Rions of Title IV of this Act. In the case of any 46 tax imposed by any part of an Act herein repealed, if 47 there is a tax imposed by this Act in lieu thereof, the 48 provision Imposing such tax shall remain in force 49 until the corresponding tax under this Act takes ef- 50 feet under the provisions of this Act. 51 Title I of the Revenue Act of 1916 as amended by 52 the Revenue Act of 1917 shall remain in force for 53 the assessment and collection of the income tax in 54 Porto Rico and the Philippine Islands, except as may 55 be otherwise provided by their respective legislatures. 56 57 SECTION 1401. That section 1100 of the Revenue 6b Act of 1917 is hereby repealed, to take efCect on July 1, 172 1919, and thereafter the rate of postage on all mall 1 matter of the first class shall be the same as the rate 1 In force on October 2, 1917: Provided, That letters 8 written and mailed by soldiers, sailors, and marines 4 assigned to duty in a foreign country engaged in the 6 present war may be mailed free of postage, subject to 6 such rules smrZ regulations as may be prescribed by 7 the Postmaster General. 8 Section 1107 of such Act is hereby repealed, to take 9 effect July 11, 1919. 10 11 SECTION 1402. That if any clause, sentence, para- 13 graph, or part of this Act shall for any reason be 13 adjudged by any court of competent jurisdiction to be 14 Invalid, such judgment shall not affect, impair, or in- 15 validate the remainder of this Act, but shall be con- 16 fined in its operation to the clause, sentence, para- 17 graph, or part thereof directly involved in the con- 18 troversy in which such judgment has been rendered. 19 20 SECTION 1403. That the Revenue Act of 1916 is 2 hereby amended by adding at the end thereof a section 22 to read as follows: 23 "Section 903. That this Act may be cited as the 24 'Revenue Act of 1916.*" 25 26 SECTION 1404. That the Revenue Act of 1917 is 27 hereby amended by adding at the end thereof a sec- 28 tion to read as follows: 29 "Section 1303. That this Act may be cited as the 30 'Revenue Act of 1917.* " 31 32 SECTION 1405. That this Act may be cited as the 33 "Revenue Act of 1918." 34 35 SECTION 1406. That all persons serving In the 36 Payment of military or naval forces of the United States durmg 37 $60 to Soldier the present war who have, since April 6, 1917, resigned 33 and Sailor or been discharged under honorable conditions (or, in 39 Upon the case of reservists, been placed on Inactive duty), 40 Honorable or who at any time hereafter (but not later than the 41 Discharge termination of the current enlistment or term of serv- 43 ice in the case of the enlisted personnel and female 43 nurses, or within one year after the termination of the 44 present war in the case of officers, may resign or be 45 discharged under honorable conditions (or, in the case 46 of reservists, be placed on inactive duty), shall be paid, 47 in addition to all other amounts due them in pursu- 48 ance of law, $60 each. 49 This amount shall not be paid (1) to any person who 50 though appointed or inducted into the military or naval 51 forces on or prior to November 11, 1918, had not re- 52 ported for duty at his station on or prior to such date; 53 or (2) to any person who has already received oneJ64 month's pay under the provisions of section 9 of thei55 Act entitled "An Act to authorize the President to in-J56 crease temporarily the military establishment of thef57 United States," approved May 18, 1917; or (3) to any^58 173 1 person who is entitled to retired pay; or (4) to the 2 heirs or legal representatives of any person entitled 3 to any payment under this section who has died or may 4 die before receiving such payment. In the case of any 6 person who subsequent to separation from the service 6 as above specified has been appointed or inducted into 7 the military or naval forces of the United States and 8 has been or is again separated from the service as above 9 specified, only one payment of $60 shall be made. 10 The above amount, in the case of separation from 11 the service on or prior to the passage of this Act, shall 12 be paid as soon as practicable after the passage of this 13 Act, and in the case of separation from the service 14 after the passage of this Act shall be paid at the time 15 of such separation. 16 The amounts herein provided for shall be paid out of 17 the appropriations for "Pay of the Army" and "Pay of 18 the Navy," respectively, by such disbursing officers as 19 may be designated by the Secretary of War and the 80 Secretary of the Navy. 21 The Secretary of War and the Secretary of the Navy 22 respectively shall make all regulations necessary for 83 the enforcement of the provisions of this section. 84 District of 25 SECTION 1407. That the provisions of section 5 of Columbia 26 the Act entitled "An Act making appropriations for 87 the service of the Post OfCice Department for the fiscal 88 year ending June 30, 1918, and for other purposes," 89 approved March 3, 1917, relating to intoxicating liquors 30 in interstate commerce, as amended by section 1110 31 of an Act entitled "An Act to provide revenue to de- 32 fray war expenses, and for other purposes," approved 33 October 3, 1917, be, and the same are hereby, made 34 applicable to the District of Columbia. 35 Persons Having 36 SECTION 1408. That ever/ person who on or after Contracts 37 April 6, 1917, has entered Into any contract, undw- with 38 taking, or agreement with the United States, or with Government 39 any department, bureau, officer, commission, board, to File Copy 40 or agency under the United States or acting in its be- Upon 41 half, or with any other person having contract rela- Request 42 tions with the United States, for the performance of 43 any work or the supplying of any materials or prop- 44 erty for the use of or for the account of the United 45 States, shall, within thirty days after a request of the 46 Commissioner therefor, file with the Commissioner a 47 true and correct copy of every such contract, under- 48 taking, or agreement. 49 Whoever fails to comply with such request of the 60 Commissioner shall be guilty of a misdemeanor and 61 shall be punished by a fine of not more than $1,000, or 68 by imprisonment for not more than one year, or both. 63 The Commissioner shall (when not violative of the 64 technical military or naval secrets of the Government) 65 have access to all information and data relating to 60 any such contract, undertaking, or agreement, In the 67 possession, control or custody of any department, 68 bureaii, board, agency, officer or commission of the 174 United States and may call upon any such department, 1 bureau, board, agency, officer or commission for a 2 full statement and description of any allowance for 3 amortization, obsolescence, depreciation or loss, or of 4 any valuation, appraisal, adjustment or final settlement, 5 made in pursuance of any such contract, undertaking, 6 or agreement. 7 8 SECTION 1409. That unless otherwise herein spe- 9 cially provided, this Act shall take effect on the day 10 following its passage. 11 175 GENERAL INDEX Index Page Individuals 3 Corporations 25 War Profits and Excess Profits Tax 49 Estate Tax 55 Transportation and Other Facilities and Insurance 57 Treasury Decisions 59 Individuals. Reference is made to Paragraph Numbers and NOT to pages. Paragraph No. Abatement — Claims for 287 Liability for tax : 287 Absence — Agent may make return for taxpayer in case of 243 Accident — Reimbursement for expenses incident to :. 94' Accident Insurance — Compensation for personal injuries 86(6) Additional Tax — Calculation of — how made 8-9 Contingent on undistributed profits 11 Dividends subject to additional tax only : 30 On individuals 7-S* Schedule of rates 7 Stock Dividends — Schedules of rates for previous years for guidance in allocating tax on stock dividends and for other purposes See page 1371 Administrator — See "Fiduciary." Advertising* Expense 109 Ag'ent — Acting under power of attorney 383, 423, 424 Commissions — See "Commissions." Of taxpayer to make return when .'.......... * 243 Alaska — Government officers and employees subject to tax 15, 15(a) Alien (Resident) — See "Resident Alien." Aliens (Non-resident) — See "Non-resident Aliens." Alimony — A personal expense, not deductible and not income to recipient 113 Amortization — Bonds — Deduction for not allowable 204 Of loss on buildings, machinery and equipment erected or installed for war purposes 197 Annnity — Taxable status of income from 97 Architect — Expense for services of a capital investment 124 Army — See also "Army Officers." Persons in service — Verification of returns 273 Army Officers — See also "Army." Expenditure from allowances 117 Retired pay subject to tax 76(a) INDEX PAGE 3: INDIVIDUALS— Continued. Paragraph No. Assessment of Tax — Five-year limitation 277 Assessments — On securities 122, 173 On shareholder of irrigation company 173 Bad Debts — Definition of 178 Amount accepted as compromise 177 Arising from unpaid wages, salaries, rents, etc 179 Bankruptcy 180 Default on installment payments 45 Due and charged off within the taxable year 176 Due prior to March 1, 1913 182 Foreclosure sale on mortgage 181 Income if collected 183 Banks- Deposits: Of foreign governments — interest on exempt 86(5) Private bank partnership 370 State tax on capital stock paid in behalf of stockholder.... 37 Tax to be wi-thheld on interest paid on bank deposits to non-resident alien 347 Bank Deposits — See "Banks." Banker — Substitute certificates of ownership of bonds 322 Bankruptcy — Status of bad debt arising from 180 Beneficiary — Of estate — To make return 261 Time of receipt of income 17 Bequest — See "Legacy." Bills of Bzchang-e— See also "License." Collection of, license required 354 to 361 Bondholder — Rentals paid directly to 31 Bonds (Securities) — Tax-free — Special distinction, for income tax pur- poses, between bonds which contain a tax-free covenant and those which do not. Read carefully 309-310. Tax Free — Status of interest under income tax See page 1375 Amortization of : .". 204 Certificates of Ownership — See "Certificates of Ownership." Certificates of ownership to be filed 297 County Bonds — Exempt 314 Coupon Bonds — See "Certificate of Ownership." Coupons due in tax year but not collected until following year 17 Coupons — Foreign — License required to collect. See "License." Depreciation or loss written off at direction of Comp- troller of Currency 170 District Irrigation Bonds — Losses on 172 INDEX PAGE 4 INDIVIDUALS— Continued. Paragraph No. Bonds (Securities) — Continued. Exempt Corporations — Owner must file certificates of ownership 313 Fidelity- Premium on allowable deduction 137 Foreign corporation — How treated for income tax purposes 321 Foreign Bonds — Collection of coupons and other foreign items requires a license 354 Collection of tax on 359 License — Penalty for failure to obtain 354-361 See also "License." Interest from: — Bonds purchased between interest dates v.. 48 Municipal Bonds — Exempt 315 Municipality — Public utility acquired by 316 Notes — Promissory note of corporation 311 Public Utility — Acquired by municipality 316 Purchased between interest dates 48 Registered Bonds — Retired within interest period 319 See "Certificate of Ownership," Scrip (dividend) — Not obligation similar to bonds M2 State Bonds — Exempt 314 Status of bonds under income tax... See page 1375 Status of interest under income tax — See page 1375 Tax Exempt — Income from, exempt 314 War Finance Corporation — See "War Finance Corpora- tion." Withholding provisions as to tax on interest from— See "Withholding at the Source." Bonds — United States — Information at the source not required 350 Income from, exempt 314 Interest from, exempt 86(4), 90 Liberty Bonds — Dividends paid in 27 Interest on indebtedness incurred to purchase not deductible, when 146 Taxable status of 89, 90 No certificates of ownership required 314, 350 Owners of must make statement of ownership 86(4) Status of bonds under income tax Page 1375 Brokers — To make return of profits of customers when required (see page 86, line 51) 352 Bonus — Bonus paid in common stock 51 Book Values — Shrinkage in 203, 205 Building- and I^oan Association — Income from shares — how treated 50 Businesses — Income from taxable 15, 15 (a) Business Insurance — Premiums paid in advance on 118 Campaign Expense 121 INDIVIDUALS— Continued. Paragraph No. Capital Assets — Stock dividend declared from revaluation of 99 Certificates of Ownership- Use of in connection with coupons and interest orders, 309(f) to 309 (j) Bonds: Coupons: Substitute certificates to bank or collecting a,gency 322, 339 Registered Bonds: Certificates of ownership not required to ac- company orders or checks in payment of interest 320, 329, 340 Containing tax-free covenant — exemption claimed.-309(h) Containing tax-free covenant 309(f) : Containing tax-free covenant — exemption waived....309(.1) Foreign Corporation — How treated 321 Forms to be filed 309(h), 309 (j) Identity of persons presented required of 343 Not tax-free 309 ( j) Read also 1[ 298 and 299. Of exempt organizations — Certificates to be filed 313 Of exempt corporations 313 Private corporation may print for own use 299 Sinking fund and similar bonds retired within in- terest period 319 ': Tax-free but not containing a tax-free covenant.... 309 (j) State, Government, Municipal and similar bonds: No certificate of ownership required 314, 350 Corporations — Certificates of 331 Foreign Partnership composed of non-resident aliens and citizens of U. S 333 May be signed by duly authorized agents 330 Non-resident aliens — Certificates of 332 Registered Bonds — Certificates not required to accom- pany interest orders 329 Substitute certificates of banks and collecting agency...... 322 Checks- Foreign checks — License required for collection 354-361 Christmas Gifts — : See "Gifts." Citizenship — Ruling on 4 American woman marrying foreigner 242 Naturalized citizens residing abroad 4 .Pity- See "Municipality." Warrants of — Face value to be accounted as income 78 Clerg-ymen — Voluntary offerings, fees, etc 84 Collection Districts — Complete list with names and addresses of collectors. See page 1365 Commis sion s — See also 'Compensation," "Salary." Deduction: Paid to real estate agent 119 Paid to salesmen 120 INDEX PAGE 6 INDIVIDUALS— Continued. Paragraph No, Commissions — Continued. Income from: On renewal premium for insurance..... — 52 Retained by agent on his own life insurance - 53 Paid for purchase and sale of securities 125 Receipt basis 18 Compen sation — See also "Salary," "Commissions." For personal service _ 15 For service on annual, monthly or weekly basis 54 Not paid in money 55, 68, 142 Payer must make return of information 350 Stockholders of close corporation 38 Contract — Loss through payment of rebates 168 Contributions — To religious, charitable, scientific or educational cor- porations '.'. 212 Copyrigfhts — Amount expended for an investment of capital 134 County — See also "State or Political Subdivision." Coupons — See also "Bonds." Due in tax year but not collected until following year 17 Credits — Individuals 104 Partnerships 377 Damagres — From injuries 86(6) Death- Deceased husband — specific exemption 239 "When either husband or wife dies during year. 238 Debts — See "Bad Debts." Deceased Person — See also "Death." Executor or administrator to make return 262 Income received by estate of 46 No penalty in delay in payment of tax for 418 Penalties enforcible and not enforcible against estate of.. 269 Personal representative to make return in case of 420 Deductions, Exemptions and Credits Allowed — See "Credits," "Personal Exemption," "Expenses,"^ "Taxes," "Losses," "Interest," "Depreciation." Deed of Trust 413 Default on Installment Payments 45 Deposits — Bank — See "Bank." Depreciation — Definition 188 to 196 Depletion: Mines — See "Mines," Oil and Gas Wells — See "Oil and Gas Wells." Timber — See "Timber." Dividends paid out of depreciation reserve 28 Estimated life of buildings 186 Fundamental principles to be observed 188 to 196 Land — Depreciation of value cannot be claimed 191, 209 Livestock purchased for breeding purposes only _ 208 INDEX PAGE 7 INDIVIDUALS— Continued. ParagraiA No. Depreciation — Continued. Obsolescence: Machinery — An important distinction 192 Of Assets — Book values 203, 205 Patents — How treated 206 Property : Building — Condemned by municipality 19ft Buildings — Estimated life of 185 Buildings — Loss due to voluntary removal or de- struction of 195 Buildings, machinery and equipment erected or in- stalled for war purposes — amortization of 197 Farm buildings, machinery, etc 208 Land — Depreciation of value cannot be claimed 191 Real estate 209, 19 Valuation fixed by cost 193 Where owner has claimed full cost as depreciation.... 193 Rate at which depreciation may be claimed 185, 186 Repairs — Cost of — how treated 187 Stage costumes 207 District Irrig-ation Bonds — Losses on 172 Dividends 19, 30 Definition IS Cash dividends 20 Declared in one tax year and paid in another 17 Stock Dividend: Court decisions on taxable status of 21 Definition of 22 Taxable at what rates 24 Value of — How computed 23 To be included in return 10-19, 29 Close Corporation — Division of profits by stockholders considered a dividend 38 Declared from special surplus 9d Federal Reserve Bank — Dividends on stock exempt 91 Dividends from stock of member banks not exempt.... 98 Foreign corporation which derives its entire income from business within U. S 295 From leased line or stock trust certificates 32 Non-resident Alien — Tax on not to be withheld 294 Paid on life insurance policies 390 Paid with securities 26 Paid in Liberty Bonds '. 27 Paid out of depreciation reserve 28 Paid by foreign corporations..... ; 33 From earnings wholly within United States 34 Received by record owner where another is actual owner 35 Scrip dividends 36, 312 Stock Dividends: Received by fiduciary 395 Subject to additional tax 30 Taxable status of 80 Taxes paid on capital stock of banks taxable to stock- holder as dividends 37, 214 District of Colombia — Income derived from public utility 86(7) Obligations of — Interest from exempt &6(4) Drainasre^ Taxes Issued for purposes of 157, 158 INDEX PAGE 8 XX^A^X V 1.U «J n.Xj\3 V/UlitlllUCU. Paragraph No. Duties — See "Customs Duties," Excess Profits Tax — Amount paid as not deductible 148 For digest of law and regulations relating to, see Index Page 49. Executor — See "Fiduciary." Exemption — See "Personal Exemption." Exempt Org-anizations — Bonds of — Certificates of ownership to be filed 313 Exempt Securities — See "Securities." Expense — Advertising 109 Allowable deductions from income as 107 to 146 Allowances to minor children 116 Architect's services — A capital investment 124 Army officers 117 Assessments on securities 122 Campaign expenses 121 Commissions — See "Comrnissions." Copyrights, plates, etc. — Amount expended for invest- ment of capital — not deductible 134 Entertainment (customers') expense 127 Fees — Earned but not paid 132 Expenses in earning income subject to tax and not sub- ject to tax 123, 126 Farmer — See "Farm." Farm Expenses — See "Farm." Gifts or contributions to religious, charitable, scientific or educational corporations 212 Lobbying expense 121 Insurance: Business insurance premiums 118 •Life and fire insurance premiums 138 Merchant, necessary 109 Personal Expenses: Alimony a personal expense 113 Not allowable deduction 112 Physician 110 Reimbursement of expense incident to accident 94 Rents — See "Rentals." Special compensation to employees 38, 144 Titles to property — Cost of defending a capital invest- ment 135 Travelling expenses — per diem allowances 73 Estate- Expenses of administering 115 Income from 46 Income from trust , 47 Returns: Beneficiary to make 261 Farm — Definition of 57 Deductions 59 Compensation of employes 129 Cost of farm' machinery and tools 130 INDEX PAGE 9 EHDIVIDUALS— Continued. Paragraph No. Vann — ^Dednctions — Continued. Cost of stock, how treated 128 Crop destroyed by storm, flood or fire 128(c) Depreciation of farm buildings, machinery, stock raised for breeding purposes 208 Expenses 59 Expense — allowable deduction as 106, 108, 111, 112 Loss of livestock 131 Orchards and ranches 114 Rehabilitation or restoration of farm 128(b) Repair expense on rental basis 130(a) Value of Land — depreciation cannot be claimed 191 Farm for recreation or pleasure 128(a) Parmer — Taxable status of 128(a) Income from: Accounting basis 61 Accounting methods 60, 61 Crop shares 59 From sale of livestock 131 How treated 56, 58 Merchandise exchanged for farm products — how valued 63 Price placed by merchant upon goods exchanged for farm produce 63 Product consumed by farmer and family 62 Rents received as crop shares 59 Rents received in crop shares 59 Taxable income defined 58 Value of product not taxable until converted into cash 60 Parxoer — See "Farm." Farm Products — See "Farm." Pcderal Farm :Loan Act — Securities issued under, exempt 86(4), 92 Ped«ral Beserve Bank — Dividends from capital stock of exempt 91 Dividends from stock of member banks not exempt 91 Pms— Earned but not paid 132 Pia-nciary — Definition 382 Administrator, ancillary 412 Agent : Acting under power of attorney 383 Acts for his principal, not for beneficiary of estate.... 415 Definition 424, 425 Agent acting under power of attorney 383 Beneficiary — tax liability 419 Deed of trust 413 Depreciation : Deduction in return of 102,414,210 Estates and trusts 388, 401 Estates — during period of administration 406 Executors and administrators 391 Expense: Estate — Expense of administering 115 . Of administration of estates not deductible 410,115 INDEX PAGE 10 INDIVIDUALS— Continued. Paragiapb No. Fiduciary — Continued. Guardians, trustees, executors as fiduciary agents to file returns 425 Income: From vested interest taxable to 16 Held for future distribution 396, 402 Income accumulated for unborn or unascertained persons 40 Of estate of deceased person during- period of administration 401 Proceeds of life insurance policies 392 Stock dividends 395 Insane person 394, 407 Minor 394 Of non-resident alien — return of 47f» Payment of Tax: Exector or administrator — liability for 421, 422 No penalty for delay, in case of insane, deceased and insolvent persons 418 Personal Exemption: Gardian — Allowance for each ward or cestui trust 220, 417 Trustee — Allowance for each cestui trust 22 Q Returns of information at the source required 431 Returns 384, 385, 380 Administrator or exector 41J Amended return not required when found subject to further tax 308 Annual return to show what 416 Beneficiary right to inspection 41?> Beneficiary to make 261 Deceased person 262, 420 Executors and administrators ,... 392 Failure to file — guardian 263 For non-resident alien beneficiary 387 Joint fiduciaries 403 Trustee 386 What to include 408 Tax: To be assessed against fiduciary direct 399 When not paid by fiduciary 400 Trust estates 398, 399, 405 Two estates 393 Unborn persons 390 Withholding at the source by 404 Estate 46 Of deceased person 46 Received in one tax year and paid in another 17 Trustee: Income from estate held by 47 Fiscal Year — Individuals: Change of: From fiscal to calendar year 247 From calendar year to fiscal year 248 From one fiscal year to another 249 First return on fiscal year basis 250 INDEX PAGE 11 IMDIVIDUALS— Continued. raragraph No. PoreclOBure — Difference between purchase price and debt not deduct- ible as bad debt 181 Poreig-n Coupons, Checks, Bills of Ezchangre 354, 361 Pire Insurcmce — Premiums paid on 138 Poreig"!! Governments — Income from investments in U. S 86(5) Taxes paid to deductible from total amount of income tax 149(a) Gas Wells — See "Oil and Gas Wells." Gift- See also "Bonus." Christmas gifts not income 93 Property acquired by 15, 15(d), 86(3) Sale of stock acquired by 75 To religious, charitable, scientific and educational corporations 212 To religious, charitable, scientific or educational cor- porations by individuals..... 212 Guardian — See "Fiduciary." Good Will — Increase or decrease in value not allowed 174 Hawaii — Government officers and employes subject to tax 15, 15 (a) Head of a Pamily — Defined 219 Dependents — allowance for 217 Personal exemption 216 Husband and Wife^ Living apart 228 Living together 229 Exemption 232 Returns of 227. 234 Separate estates 233 Separate returns, when 231 Separated and living apart 230 Single or married status, when determined 241 Taxable status 226 Wife — Income from special articles (magazine) 240 Wife — separate estate managed by herself 235 When either dies during year 238 When either has income of $1,000 or over 236 When income of both in ercess of $2,000 237 Wife — American women marrying foreigner takes na- tionality of husband — Cannot claim exemption 242 Income — See also "Compensation," "Salary." Gross Income — definition 15 What it includes 15 Inventory to determine, when necessary 175 Net Income: Definition * 12 How computed 13, 14 Allowance for expenses 73 Bonus 80 Exempt from tax 86 INDEX PAGE 12 INDIVIDUALS-Continued. Paragraph No. Income — Continued. Fees '.'. 8^ From Life Insurance — See "Life Insurance." From sale of personal property on instalment plan 44, 45 From sale of property 43, 45 From sale of stock, securities, etc 72 Interest — See "Interest." Mileage - 69 Payer of Income to another must make return of in- formation - 35*0 Pensions 71 Receipt basis ^ _ 18, 54 Royalty : 77 Time of accrual 17 Travelling expenses 73 Warrants of city or town 78 Income TaK — Additional Tax — See "Additional Tax." Evasions of tax, penalty 285 Laws of other countries 6 Normal Tax — See "Normal Tax." Not deductible from taxable income ...133, 14% Payment of — "Payment of Tax." Payments of — See "Payment of Taxes." Who and what taxable - 1-6 Withholding of at source — See "Withholding at the Source." Inheritance — See "Legacy." Information at the Source — Broker.s — To make return of profits of customers when required (see page 86, line 51) 3512 Dividends — Corporations to make return of dividends paid on request of Commissioner (see page 86, line 41) 350(a) Individuals, partnerships and corporations required to make return of income paid to another 350* Obligations of U. S. — return not required 35,r9 Where person receiving payment is not the actual owner of income 345 Illness — Agent may make return for taxpayer in case of 243 Insane Person 394^ 418 Insolvency — No penalty for delay in payment of tax for 418 Installment Payments — Income from sale of property paid by 44, 45 Loss from default of — how computed 45 Of income tax — See "Payment of Tax." ^: Insurance- Accident Insurance — See "Accident Insurance." Business Insurance — See "Business Insurance." Fire Insurance — See "Fire Insurance." Health Insurance — See "Health Insurance." Life Insurance — See "Life Insurance.'^ Workmen's Compensation Insurance — See "Workmen's Compensation Insurance." Interest — Deductible from income 145 INDIVIDUALS— Continued. Paragraph No. Interest — Continued. Income from 15, 15 (a) Bonds — See "Bonds," "Bonds — United States." Obligations of State, Territory, County, Municipality, etc 86(4) Return of information at source required of payer 350 Tax-free Bonds — See "Withholding at the Source." Xnvestment Certificates 310 Inventories — Individual: To be taken when necessary to determine income 175 Dealer in securities 205 Investment Certificates — Status of 32, 310 Irrig'ation District — See also "Irrigation Corporations." Taxes assessed by I57 Jndg-es — Of Supreme and inferior courts subject to tax 15, 15(a) Knig-hts of Columbus — Contributions to 212 landlord — - ^ Permanent improvements made by tenant 42 1 Taxes paid by tenant 143 lawyer — See "Professional Man," "Fees," "Physician." Ziease — Permanent Improvements made under 42 IJeased Iiine Certfiicates — Income from considered to be dividends 32 Legracy — Property acquired by i 16, 86(3) lessee (Corporation) — Rentals paid directly to bondholder or stockholder 31 Liberty Bonds — See "Bonds — United States." License — Annual list return 358 Application for 355 Branch offices — 35*6 License to furnish list 357(a) Licensee to keep records 360 Penalty for failure to obtain 356 Required for collection of foreign coupons, checks, bills of exchange 354 Life Insurance- Amount received in excess of premiums taxable 64 Business insurance premiums 118 Dividends from policies 39, 65, 98 Endowment contract 97 Endowments — Income from 66 Premiums paid on 138 Premiums paid on lives of officers and employes 372 Proceeds of paid on death of Insured... 86(1) Proceeds of payable to estate of decedent 392 Return of premiums .....86(2) INDIVIDUALS— Continued. , Pai No. Xdvestock — Cost of — how treated - 128 Depreciation in value of - 208 Loss of through death .' - 131 Sales of — Income from — 131 Xiving: Quarters Fnmished in Addition to Salary 55,68 Uqnidation — Of assets — how valued _. 25 laobbying* EKpense 121 Xiocal Benefits — Defined „ 157 Taxes assessed against not allowable deductions 157, 158 XK>sses — Individuals: Definition * 163,168 All losses deductible _ 162 Assessment on stock 173 Bad Debts — See "Bad Debts." Bankruptcy — See "Bad Debts." Default on installment payments 44(4) Foreclosure — See "Bad Debts." Good Will — Capable neither of appreciation nor depreciation — 174 Inventory: Losses from reduction in value of „ 166 Not to be confused with "depreciation" - 168 Property: Loss of 164 Rebates: Losses from payment of 166 Mileagre— Amount received as, how treated ™ 69 Military Forces — See "Army." Mines — Depletion and depreciation allowance defined 198 to 202 Minor _ 394 Mortg-agre — Foreclosure — Difference between purchase price and debt not deductible 181 Security — See "Bonds." Municipality — See also "State or Political Subdivision." Bonds of — Certificates of ownership not required 315 Bonds of — Exempt from tax 315 Bonds of Public Utility acquired by „ 816 Bonds — Public Utility acquired by — Income from not exempt 316 Taxes against local benefits — definition 158 Warrants of city — ^Face value to be accounted as income 78 Vatnral Deposits — Depletion allowance defined 198 to 202 Wavy — Verification of returns of persons in service 27S Von-resident Aliens — Definition 432 American wife of _ 434 Bonds of — Tax on interest to be withheld and paid at source 318 INDIVIDUALS— Continued. Paragraph No. Non-Resident Aliens — Continued. Certificate of ownership to be filed 333 Deductions: Conditioned on filing a return 438, 454 Contributions, gifts ■. 466 Deductions allowed 455 Depreciation 46S ' Mines, oil and gas well 464, 467 Expenses 456 Interest 457 Other deductions 468, 469 Losses 459, 460, 461 Taxes 45« Fiduciary of: To render return, when 477 Credits 470, 471 Employed by domestic corporation — Tax on salary not subject to withholding 361 Income: Compensation for services rendered abroad, exempt.. 439 Dividends .....442, 443 Dividends: Foreign corporations 444 Record owner other than non-resident alien in- dividual actual owner, and is non-resident alien 451 Record owner non-resident alien corporation 452 Record owner liable for tax 446 Record owner to mark return and pay tax 447 Returns of — Actual owner non-resident alien corporation ,441? Actual owner a non-resident alien indi- vidual :44'P Actual owner non-resident alien partnership 450 Exempt income 47$ Income subject to tax.. 437 Royalties 440 Salary, rents paid to by domestic corporations or res* .: ident individuals : ., 480 , Sale of stocks 441 Interest on bank deposits — Tax on to be withheld 347 Notes — Tax on interest from to be withheld 349 Refund, on return 487 Returns: Agents or representatives to make 472, 477, 478 Conditions i. 438 Dividends i. 442 Failure to file — Notice to be sent to guardian 263 Liability to make 473 Return in behalf of by commissioner 474 Resident Aliens — defined for tax purposes ;43S Residence: . Method of establishing residence - 45j5 Permanently located in U S. but with domicile out- side U. S m ; Temporary residence in U. S _.....i 433 Stock — Certificate to disclose ownership ^* 447 Temporary residence in U. S „ :. 433 Verification of return required 271, 272 INDIVIDUALS— Continued. Paragraph No. Non-Besident Aliens — Continued. Withholding provisions of law as applied to income, 291(a), 291(b) Tax on dividends exempt from withholding 294 Withholding tax at source of income 478 When all tax not withheld 479 Normal Tax — How calculated 8-9 On citizens and residents 1-2 On naturalized citizens residing abroad 3 On non-resident alien individuals 1-3 Upon what computed 12 Notes — Promissory — See 'Promissory Notes." Notes 311 See also "Bonds." Oaths- Returns to be made under 271 to 273 Obligfations of United States — See "Bonds — United States." Of State — See "State or Political Subdivision." Oil and Gas Wells — Depletion and depreciation allowed as deduction 198 Orchards — See "Farm." Partnerships — Credits allowed 377 Composed of non-resident aliens and citizens of U. S 333 Deductions: Life insurance premiums on lives of officers and employes — not deductible 372 Taxes deductible by members of 149(a) Fiscal year of 378 Income of Member of: How computed 368, 376 Identity of 373 Individual profits 379 Partnership profits to be included 369 W^hen accrued 371 Limited partnerships 40 Members of liable for tax in individual capacity 368 Private bank partnerships 370 Returns — of information of all payments of over $1,000 made to individuals, fil'ms, corporations 350 Taxes: Foreign taxes — 146(a), 147 to 152 Read especially 149 to 153 Paying* Agfent-^ Bond Interest — Corporations may appoint 335, 336 Returns of — See "Withholding at Source." Payment of Tax — Abatement of taxes (see "Abatement) 287 At the source — See "Withholding at the Source." Evasion of payment, penalty 285 Excess payment of tax — how treated 281 Failure to pay ....:.....• 286 Failure to Pay: '. No penalty in case of insane, deceased and Insolvent persons ......-:....::......!..: 418 INDIVIDUALS— Continued. Paragraph No. Payment of Tax — Continued. Instalment payments 258 Payment optional 260 Receipt for to be given on request 279 Taxes withheld at source 304 When extension of time for filing return is granted 259 Penalties — Death — Ad valorem penalties to be enforced regardless of 269 Death — Specific penalties unenforcible in case of 269 Evasion of tax 285 False returns 268, 284 False Return: F'raudulent return — penalty 283 Understatement of income 280, 284 Failure to file returns ^ 267, 283 Failure to pay tax: None in case of insane, deceased or Insolvent persons 418 Withholding agent for divulging information 307 Pensions 71 Personal Exemption — Allowed to each ward or cestui trust 417 Dependents — allowance for 217 Guardian 220 Head of a family 216 Head of a family — definition 219 Husband and Wife — Taxable status of — See "Husband and Wife." Married person 216 Single person 218 Trustee 220 Personal Service Corporations — Not subject to tax as corporations 41 To make returns as partnerships 41 Philippine Islands — Taxes imposed by — See "Taxes." Obligations of — Interest on exempt 86(4) Physician — Expense deduction 110 Plates (Publishers) — Amount expended for an investment of capital 134 Porto Rico — Obligations of — Interest on exempt 86(4) Taxes imposed by authority of — See "Taxes." Power of Attorney — Fiduciary relationship cannot be created thereby 424 Premiums- Fidelity bond 137 Insurance — See "Fire Insurance," "Life Insurance." Paid on life Insurance of officers or employes 372 Profession — See also "Fees," "Physician." Rent Tor residential property 140 Promissory ITote of Corporation 311 Property — See also "Real Estate." Losses in connection with — See "Losses." Method of determining value of 45 Income from sale of 43-45 INDIVIDUALS— Continued. Paragraph No. Property — Continued. Permanent improvements made under lease or rental contract - *2 Title to — Cost of defending a capital investment 135 Private Bank — See "Bank." Profits — Undistributed, tax contingent on 11 President of United States — Income subject to tax 15(a) Promissory Note of Corporation 311 Public TTtiUty— Bonds of acquired by municipality not exempt 316 Income from accruing to State, Territory, political sub- division and District of Columbia..... 86(6) Ranches — See "Farm." Seal Estate — See also "Property." Depreciation of — See "Depreciation" 209 Foreclosure of mortgage on — See "Bad Debt." Installment payment on — See "Installment Payments." Permanent improvements made under lease or rental contract 42 Rebates — Loss from payment of under contract 166 Red Cross (American) — Contributions to 212 Refund — of tax for 290(b) Reclamatior— Taxes assessed for purposes of 157 Reimbursement— Of expense incident to accident 94 Rentals — Amounts expended for taxes or repairs by tenants....76, 143 Paid directly to bondholder or stockholder — Bad debts arising from unpaid 179 Permanent improvements made under lease or rental contract 42 Room and board furnished employe as part of compen- sation 142 Return of information at the source required of payer 350 Residential property 140, 141 Sale of leasehold — deduction 139 Taxes paid by tenant to landlord 143 Repairs — Cost of — How treated in computing "depreciation" 187 Reporting* at the Source- See "Information at the Source." Residence — Rental 140, 141 Resident Alien — Defined lor tax purposes 435 Taxes paid or accrued to a foreign country 153 Taxes paid or accrued to a Possession of U. S 153 Returns — Collector to make in certa^ cases 264 INDIVIDUALS— Continued. Paragraph No. Returns — Continued. Failure to File: "Reasonable cause of" defined 278 Refund of portions of amount paid as penalties for failure to file for year 1913 266 2% penalty — Disclosre of liability to file prevents.... 267 Written waiver of exemption after expiration of time limit 270 False Return: Defined 265 Fraudulent penalties 268, 284 Extension of time — citizens residing abroad, non- resident and alien corporations 276 Extension of time to citizens of U. S., non-resident individuals abroad '. 276 Filing of: Individual having no legal residence or place of business in U. S 253 Where filed 252 Forms of , 243(a) • Forms of — What to contain 254 Individual — Adjustment of tax by commissioner 256 Agent for taxpayer — to make return, when 243 Amended return not required when individual found ; subject to further tax 255 Dividends to be included in 245 Fiscal year return basis — See "Fiscal Year." Fiscal year — See "Fiscal Year." Mailed returns 244 Non-resident aliens — See "Non-resident Aliens." Period to be covered by return unless changed to a fiscal year >. 246 Who shall make, when made 243 Verification of: Understatement of Income: Penalty 5% of deficiency plus 1% 250 Oaths — Who may administer 272 Persons in naval or military service 7. 273 To be verified under oath 271-273 United States Bonds — Owners to make statement wltli return 86(4) Withholding agents — See "Withholding at the Source." Royalty- Income from taxable 77 Salary — Bad debts arising from unpaid 175 Earned in one year and not paid until next year 17, bi^ Foreign employe — Not subject to withholding at source.. 361 Included as income 15 Non-resident alien individual, paid by resident individual or domestic corporation, exempt : 480 Paid after death lOd Paid by organizations exempt from tax : 82 Payer must make return of information 350 Salary and bonus ^. :..... 79 Salary and commissions ^ 19 Two years' salary paid conditionally .,-,.... , . 85 INDIVIDUALS— Continued. Paragraph No. Salvation Army — Contributions to 212 Securities — Assessments on 122 Book values — Shrinkage in 203 Commissions paid for purchase and sale of 125 Dealers in 203, 205 Exempt securities — Income from, how treated 96 Investment certificates 310 Investment certificates 310 Issued by War Finance Corporation, exempt 12(b), 86(4) Issued under Federal Farm Loan Act 86(4) Owned by foreign governments 86(5) Leased line or stock trust certificates — taxable status.... 32 Promissory note of corporation 311 See also "Stocks," "Bonds," "Bonds — United States." Value reduced at direction of Comptroller of Currency.... 170 Sta£re Costmnes — Depreciation 207 State or Political Subdivision — Bonds of — Certificate of ownership not required 315 Bonds of — Interest from exempt 314 Contractor with — Status of 70 Expense incurred in earning income not allowable deduc- tion 101 Income derived from public utility 86(7) Obligations of — Definition 88 Obligations of — Interest from exempt 85(4) Obligations of — Interest on exempt from tax 86(4) Officer or employee of — definition 70 Political subdivision — Definition 87 Taxes imposed by — See "Taxes." Warrants issued by '.... 78 Stock Dividend — See "Dividends." Schedules of rates for previous years for guidance in allocating tax on stock dividends and for other purposes See page 1371 Stockholder — Of corporation to be taxed on undistributed profits — when 11 Rentals paid by lessee directly to 31 Stock (Securities) — Bonus in common stock 51 Dividends on — See "Dividends." Profit from sale of — how treated 72 Profit from sale of lots purchased at different times 72 Profit from sale of stock acquired by gift 75 "Rights" '(subscription) income from 74 Stock Trust Certificates — Income from considered as dividends 32 Tariff- See "Customs Duties." Taxes — Against Local Benefits: Local Benefits defined 157, 158 Not Allowable Deduction — Law, page 62, line 48. INDEX PAGE 21 INDIVIDUALS— Continued. Paragraph No. Taxes — Continued. As Expense or Deduction: Paid by tenant as part of rent 76 Customs duties are part of cost of goods 155 Deductible from income 147 By beneficiary of an estate 149(a) By member of a partnership 149(a) Porto Rico and Philippine Islands — Imposed by authority of 149 State, county and municipal taxes 150 United States — Imposed by authority of 149 Deductible as Rental: Paid by tenant to landlord 143 Deductible from Total Amount of Tax: Income, war profits and excess-profits taxes imposed by U. S. Possessions and foreign countries 149 Foreign Taxes 146(a), 149 to 152 Foreign taxes — (paid to foreign countries) 149(b) Imposed by United States Gov't — Read H16(a) and Us 147 to 152. Income taxes not deductible 133 Local benefits — Taxes against not deductible 150, 157 Not Deductible from Income: Imposed by Philippine Islands, Porto Rico 149 Income, war-profits and excess-profits taxes 14 Paid in behalf of stockholder by bank on capital stock allowable deduction 37, 214 Paid to foreign country deductible from total amount of income tax 149(b) Philippine Islands: Taxes imposed by 146(a), 149 to 152 State or Political Sub-division: Taxes imposed by 150 U. S. Gov't — Taxes imposed by — Read tI146(a) and Us 147 to 152. Tax— free Covenant — See "Bonds." Tenant — Permanent improvement made by 42 Repairs made by, as part of rent 76 Taxes paid by as part of rent..... 76, 143 Territory — Interest from obligations of 86(d). Timber — Depreciation and depletion allowed 198 to 202 Loss by fire of standing timber 165 Town — See "Municipality." Treasury Decisions — Promulgated under Acts of 1916 and 1917 for guidance of those who are required to make amended returns for those years. (See Index to Treasury Decisions.) Trustee — See Fiduciary. Treasury Decisions — Effective date of 38t Trust Companies — See "Banks," INDEX PAGE 22 INDIVIDUALS— Continued. Paragraph No. Undistributed Profits — See "Profits." U. S. Government — Bonds of — See "Bonds — United States." Government officers and employes: Compensation not paid in money 95 Taxable status of income 95 Liberty Bonds — See "Bonds — United States." Officers of — Income subject to tax 15, 15(a) President of — See '-President of United States." Securities issued by War Finance Corporation — See "Securities." Taxes deductible from income 149 Taxes imposed by authority of — See "Taxes." Vocations — Income from taxable 15, 15(a) Wagres — See "Salary." War Finance Corporation — Securities issued by, exempt 86(4), 12(b) War-Profits Tax — Amount paid as not deductible 149, 150 Warrants of City or Town 78 Wife- Taxable status — See "Husband and Wife." Withholdingf at the Source — Bond — Certificates of ownership — See "Certificates of Ownership." Bond Interest — Tax on: Amount of tax to be withheld 308 Bonds containing tax-free covenant 309 Bonds without tax-free covenant — Payment cannot be made) at source 309(e) Citizen or Resident — May file certificate of ex- emption 309(a) Exempt organization — Certificates to be filed — 313 No withholding when individual exemption claimed. 309 (b Of 2% to be deducted from income of citizen or resident or non-resident alien individual 309 Owners not known to withholding agent — Commis- sioner may authorize deduction 309 Tax-free Bonds — Important distinction for income tax purposes 309(f) Tax-free bonds — issued with and without tax-free covenant — Important distinction 309(e), 309(f) Varying policy of corporations 309 Tax-free bonds only 308, 309 Tax-free covenant — Contract between corporation and bondholder 309(c) Tax withheld only a partial tax 309(d) Exempt organizations subject to provisions of lav/ 293 Fiduciaries 404 Foreign corporations 291(b) Non-resident alien individuals 291 (a) Non-resident alien — Tax on dividends not to be with- held 294 Non-resident Alien : Interest from bank deposits — Tax on 347 Interest from notes 348, 349 INDEX PAGE 23 INDIVIDUALS— Continued. Paragraph No. Withholdinsf at the Source — Continued. Payment of tax withheld 304 Provisions of the act, as applied to citizens, residents and non-resident aliens 291 Also see Law, page 69, lines 27-48. Returns: Of information at the source. See "Information at the Source." Withholding Agent: Annual return of 305 Bond interest — Non-resident aliens 312 Corporation may appoint paying agent 335, 335 Defined 317,292 Monthly Return of , 306 Non-resident aliens 318 Paying agents 317 Payments of tax withheld 304 Penalty for divulging information 306 Returns of: Annual return 305, 344 Monthly list 304, 306, 344 Monthly List — Duplicates to be filed 338 Monthly list— Where filed 337, 344 Penalty for divulging information.. 307 Salary of foreign employe exempt 361 Withholding- Ag-ent — See "Withholding at the Source." Workmen's Compensation Insurance — Compensation for personal injuries 86(6) Voung' Men's Christian Association — Contributions to 212 INDEX PAGE 24 Corporations. Reference is made to Paragraph. Numbers and NOT to pases. Paragraph No. Assessments — Additional 779 Acconntingr — See "Bookkeeping." Additions and Betterments — Not deductible 593 Siding or spur traclvs 605a Affiliated Corporations — Consolidated returns by specific exemptions allowable — definition of 711 Agricnltural Orgranizations — See "Exempt Corporations." Amortization — Buildings, etc., constructed for war purposes 651 Bonds 201 Bonds, discount and expense 663 Assessments — Additional 779 Assets — Carrying charges 577, 594 See "Capital Assets." Associations — Definition of 490, 491 Limited partnerships 495 Private banks 497 Bad Debts — Arising from unpaid wages 638 Doubtful accounts 636 Loss must be definite 637 Recovered 639 When determined 635 Bankruptcy — Bad debts charged off 180 Banks — Bank stock taxes 687 Gross income of 550-720 Interest paid on deposits or investment 611 Banks and Other Financial Institutions — Gross income defined as taxable 720 Boards of Trade — See "Exempt Corporations." Bonds (Securities) — Tax-free 684 Discount and expense to be amortized 663 Discount on, not deductible 662 • Tax-free — Special distinction, for income tax pur- poses between bonds which contain a tax-free covenant and those which do not. Read carefully 309-310. Tax-free Covenant — See 309 CORPORATIONS— Continued. Paragraph No. Bonds (Securities) — Continued. Tax Free — Status of ihterest from under income tax — See page....l375 Amortization of 204 Certificates of Ownership — See "Certificates of Ownership." Certificates of ownership to be filed 297 County Bonds — Exempt 314 Coupon Bonds — See "Certificates of Ownership." Coupons due in tax year but not collected until following year 17 Coupons — Foreign — License required to collect. See "License." Depreciation or loss written off at direction of Comp- troller of Currency 170 District Irrigation Bonds — Losses on... 172 Exempt Corporations — Owner must file certificates of ownership 313 Fidelity — Premium on allowable deduction .^ 137 Foreign Corporation — How treated for income tax purposes 321 Foreign Bonds — Collection of coupons and other foreign items requires a license 354 License — Penalty for failure to obtain 354 See also "License." Interest from — Bonds purchased between interest dates 49 Municipal Bonds — Exempt 315 Municipality — Public utility acquired by 31$ Notes — Promissory note of corporation _... 311 Public Utility — Acquired by municipality 316 Purchased between interest dates 48 Registered Bonds — Retired within interest period 319 See "Certificate of Ownership." Scrip (dividend) — Not obligation similar to bonds 312 State Bonds — Exempt 314 Status of bonds under income tax See page 1375 Tax Exempt — Income from, exempt 314 State Bonds — Exempt 314 War Finance Corporation — See "War Finance Corpora- tion." Withholding provisions as to tax on interest from — See "Withholding at the Source." Bonds — United States — Information at the source not required 315 Interest from exempt 86(4), 90 Liberty Bonds — Dividends paid in 27 Interest on indebtedness incurred to purchase not deductible, when 146 Taxable status of 89, 90 No certificate of ownership required 314, 315 Owners of must make statement of ownership 86(4) Income from, exempt 314 CORPORATIONS— Continued. Pi No. Bonuses — _ Bonus paid in common stock 51 Special payments 614 Taxable status of , 80 Books — Examination of 778 Bookkeeping* — No particular system - 774 Book Values — Shrinkage in 203,205 Brokerage — Interest received by 585 Building: and Zioan Association — Income from shares — ^how treated :. 50 Without capital stock, operated for mutual purposes, without profit .— 527 Business Zieag-ues — See "Exempt Corporations." Capitalization — Capital Stock — Delinition of 543 Donations 545 Of lessor companies— not. to be included by lessee companies .— . 515 Paid-up — 542 Received by a corporation 544 Capital Assets — Drawings, Models, Etc. — Expenditure for 667 Value of — When exchanged for capital stock 576 When sold to other corporation 578 When sold by subsidiary to. parent company 579 Capital Stock — See "Premium and Discount." Certificates of Ownership — Use of in connection with coupons and interest orders, 309(f) to 309(j) Banks and trust companies — Execution of 343 Bonds: Coupons- Substitute certificates to bank or collecting agency , 322, 339 ,, Registered Bonds: Certificates of ownership not required to ac- company orders or checks in payment of interest 320, 329, 340 Containing tax-free covenant 309 (f ) Containing tax-free covenant — exemption claimed..309(h) Containing tax-free covenant — exemption waived.. ..3 09 (j) Foreign Corporation — How treated - 321 Forms to be filed 309(h), 309 (j) Identity of persons i)resented required of 343 Not tax-free 300 (j) Read also t|298 and 299. Of exempt organizations — Certificates to be filed 313 Private corporation may print for own use 299 Sinking fund and similar bonds retired within in- terest period , 319 CORPORATIONS— Continued. Paragraph No. Certificate of Ownership— Continued. State, Government, Municipal and similar bonds: No certificates of ownersiiip required 314, 315 Tax-free but not containing a tax-free covenant 309 (j) Corporations — Certificates of 33i Foreign Partnership composed of non-resident alien cor- porations and citizens of U. S 333 May be signed by duly authorized agents 330 Non-resident alien corporations — Certificates of 332 Registered Bonds — Certificates not required to accom- pany interest orders 32d Substitute certificates of banks and collecting agency 322 Chambers of Conuuerce-— See "Exempt Corporations." Charitable Organizations — See "Exempt Corporations." Checks — Uncertified — Liability for payment of 763 Cemetery Companies — See "Exempt Corporations," Citizens of 17. S. — Possessions 773 City- See "Municipality." Warrants of — Face value to be accounted as income.. 78 Civic Zieagnes — See "Exempt Corporations." Close Corporations — Compensation of officers 38 Liable to tax 502 Clnbs — Pleasure or Recreation — See "Exempt Corporations." Collection Districts — Complete list with names and addresses of collectors. See page 1365 Compensation — Of individuals composing company with two stockholders 561 Commissions — Deduction: Paid to real estate agent 119 Paid to salesmen 120 Common-Iiaw Partnerships — Not associations 496 Contracting- Companies- Income — see "Corporations" 503 Co-operative Associations — See "Definitions." Co-operative Dairy — See "Definitions." Copyrights — ■ Amount expended for an investment of capital 134 Corporations — Definition of 490 Dividends — Return of dividends paid when required by Commis- sioner (See page 86, line 41) 351 Affiliated 711 As withholding agent 334 CORPORATIONS— Continued. Paragrapn No. Corporations — Continued. Banks and other financial institutions 720 Bonds — shrinkage in value of ...i.. 172 Capitalization — See "Capitalization." Change of name of 518 Close Corporation — Division of profits considered to be dividends to stockholders 3$ Contracting Companies — Income of 503 Dissolved 494 Domestic 711 Domestic, doing business in foreign country must make return 504 Exempt — See "Exempt Corporations." Foreign 691 Foreign, with office in United States — Designate principal office 516 Incomplete 493 Information Returns — Of all payments over $1,000 made to another corpora- tion, firm or individual 350 Irrigation — Assessments on stock of 173 Manufacturing 721 Mercantile 722 Miscellaneous — income defined 555 New — Fiscal year returns 517 New — Fiscal year — returns of 744 Notes of — Promissary notes 311 Operating corporation controlled by stock ownership 556 Organized — During year make returins 519 Personal Service — Definition 541(a) Payment agent — corporation may appoint 335 Personal Service Corporations — See "Personal Service Corporations." Philippine and Porto Rican corporations — Tax on 492 Premiums paid on lives o officers not expense 616 Promissary Note of — Taxable status 311 Property taken over in exchange for stock 571 Receivers, trustees or assignees to make return 728 Returns of — Mutual telephone 501 Mutual insurance 501 Consolidated 711 Close corporations 502 Sinking fund investments 56 4 Sinking fund reserve 563 Tax on 488 INDEX PAGE 29 CORPORATIONS— Continued. Paragraph No. Corporations — Continued. Treasury stock — When taxable 566 Voluntary payments by stockholders 566 County — See also "State or Political Subdivision." Conpons — See also "Bonds." Due in tax year but not collected until following year.... 17 Exchange of — For funding purposes , 568 Credits — Allowed as deduction ,., ..., - 548 Example of 690 Excess-profits tax 686 Cnstom Duties — Deductible as expense 688 Dairy — Co-operative — See "Definitions." Debts — See "Bad Debts." Deductions — Allowable -- 586 Bad Debts — See "Bad Debts." Dividends — See "Dividends." Dividends — See "Dividends." Expenses — See "Expenses." For depreciation 72S For general expenses ;. - 724 Bad debts :. 725 For interest on indebtedness 727 For Losses: Insurance Companies — See "Insurance Companies." Interest — See "Interest." Losses — See "Losses." Operation and maintenance 588 Rent — See "Rent." Taxes — See "Taxes." Deed of Trust 418 Default on Installment Payments 48 Definitions — Associations 490, 491 Clubs, exemption 538 Co-operative associations 537 Co-operative dairy 536 Corporations : 496 Insurance companies 490 Joint-stock companies : •. 490, 491 Paid 596 Paid or accrued and paid and Incurred 596 Society or association exemption _ 683 INDEX PAGE 30 CORPORATIONS— Continued. Paragraph No. Definitions — Continued. Social clubs, exemption 1 534 Taxable year 489 Taxable period 489 Depletion — Mines, oil and gas wells 632, 676, 677 Depreciation — Deductions for 726 Allowance for property 646 Assets subject to wear and tear 650 Cost of buildings, not allowed 618 Diversion of funds 653 Estimated value, when 652 Improvements 675 Life of buildings 649 In excess of cost 655 Mines, oil and gas wells 63S Must be charged ofC 657 Patents 666 Rate for computing 648 Reserve 654 Reserve 654, 656 Securities 660 Shrinkage in book values 658 Stocks and bonds 659 Disclosure of Information in Return — Penalty 771 Discount — On bonds not deductible , 662 Sale of capital stock 583 Dissolved Corporations — Liability for tax 494 District Irrigation Bonds — Losses on 172 District of Columbia — Income derived from public utility 86(7) Obligations of — Interest from exempt 86(4) Dividends — Definition 19 Cash dividends 20 Close Corporation — Division of profits by stockholders considered a dividend 38 Declared from special surplus 99 Declared in one tax year and paid in another 17 Deductions from gross income 598 Deductible 645 Earnings or dividends from subsidiary companies not deductible by parent or holding company 560 Federal Reserve Bank — Dividends on stock exempt.... 91 Dividends from stock of member banks not exempt.. 92 Foreign corporation which derives its entire income from business within U. S 295 From leased line or stock trust certificates 32 Non-resident Alien Corporation — Tax on not to be with- held : 294 Paid with securities 26 Paid in Liberty Bonds 27 Paid out of depreciation reserve 28 Paid by foreign corporations 83 From earnings wholly within United States S4 INDEX PAGE 31 CORPORATIONS— Continued. Paragrapl) Dividends — Continued. No. Private banks 498, 499 Received by record owner where another is actual owner 35 Return of ., 753 Scrip dividends 36, 312 Stock Dividends: Court decisions on taxable status of 21 Definition of 22 Received by fiduciary 395 Taxable at what rates 24 Value of — How computed 23 Subject to additional tax 30 Taxes paid on capital stock of banks taxable to stock- holder as dividends 37, 214 Domestic Buildingr and I^oan Associations — See "Exempt Corporations." Domestic Corporations — Indebtedness of 719 Instructions re making returns of annual net income .... 716 Returns on stock owned in foreign corporation 711 What constitutes capital stock in making return 718 Donations — See "Expenses" Not deductible 628 "When donations are deductible." Drainag^e— Taxes issued for purposes of 157, 158 Drawing's, Models, Etc. — See "Losses." See "Capital Assets." Obsolescence 669 Duties- See "Customs Duties." >, Edncational Organizations — See "Exempt Corporations." ISzamination of Books 778 Dzcess Profits Tax — Amount paid as not deductible 148 For digest of law and regulations relating to, see Index page. Sxempt Corporation — Income from bonds of 313 Exempt Organizations — Bonds of — Certificates of ownership to be filed 313 Conditional 520 Unconditional — Boards of Trade 522 Business League 522 Cemetery companies 522, 535 Charitable organizations 522 Chambers of Commerce 522 Civic Leagues 522 Clubs — Pleasure or Recreation 622 Domestic building and loan associations 522, 527 Educational organizations « 522 Farmers', Fruit Growers' or like associations — mar- keting on mutual basis 522, 535a Farmers' or other mutual insurance company 522 Mutual ditch or irrigation 522 Mutual or co-operative telephone 522 INDEX PAGE 32 CORPORATIONS— Continued. Paragraph No. Exempt Org-anizations — Continued. Federal land banks <... 522 Fraternal beneficiary societies 522 Holding companies — title to property 522 Humane organizations 522 Labor agricultural or horticultural organizations..522-526 Mutual savings banks 522 Personal service corporations, conditional 522 Qualifications for 528 Religious organizations 522 Scientific organizations 522 See "Exempt Organizations." Exempt Org-anizations Bonds of — Certificates of ownership to be filed 297 Salaries paid by subject to tax 82 Withholding of tax at source 293, 291, 346 Exempt Securities — See "Securities." Exemption — See "Credits." Clubs- See "Definitions." Doubtful — Organizations to make return 528 Established 530, 531 Social Clubs — See "Definitions." Society and Association — See "Definitions." Expenses — Advertising 109 Allowable deductions for 587 Architect's services — ^A capital investment 12i Assessments on securities 122 Bonuses or additional compensation 614 Campaign expenses 121 Charges against current earnings 597 Commissions — see "Commissions." Commissions paid salesmen 621 Compensation paid in stock 62? Company composed of two stockholders 561 Copyrights, plates, etc. — Amoimt expended for invest- ment of capital — not deductible 134 Cost of improvements 592 Cost of material .' 589 Customs duties deductible 688 Deductions for general expenses 724 Depositors' guarantee fund : 591 Donations deductible, under certain conditions 627 Earnings — Public Utility 602 Entertainment (customers') expense 127 Incidental repairs 590 Import or tarifC duties 689 Insurance: Business insurance premiums 118 Fire insurance premiums 138 Lobbying expenses 121, 601 INDEX PAGE 33 CORPORATIONS— Continued. Paragraph No. Expenses — Continued. Maintenance : 608 Merchant 109 Operation and maintenance 588 Operation and maintenance 613 Payment for labor and material 609 Pensions paid employes, deductible 624 Rents — See "Rentals." Salaries paid officers and employes 595 Salary drawn from own business 38, 145 Special compensation 626 Special compensation to employees 18, 144 Spending money 600 Sale of capital stock 603 Taxes — see "Taxes." Tenant corporations 604 Titles to property — Cost of defending a capital invest- ment 135 Traveling expenses — per diem allowances , 73 liztension — Collectors may grant, in case of sickness or absence 509 Commissioner may grant for good reason 510 Farmers' and Pmit Growers' Associations — See "Exempt Corporations." Parmers' or Other Mutnal Insurance Companies — Federal Farm I^oan Act — Securities issued under, exempt 86(4), 92 See "Exempt Corporations." Federal Iiand Banks — Federal Reserve Bank — Dividends from capital stock of exempt 91 Dividends from stock of member banks not exempt 91 See "Exempt Corporations." Fiscal Year — Amended instruction for guidance in determining 746 Collectors must make designation of , 747 Computation basis 745 Corporation — Computation of tax 547 Of New Corporations — Returns of net income for — How made 744 Foreclosure — Difference between purchase price and debt not deducti- ble as bad debt 181 Foreisru Corporations — Deductions allowable 693 Deductions — How evidenced 707 . Income in United States subject to withholding — Income — Withholding of tax on at source 291(b) Amortization — Deductions allowable 705 Bonds of — How treated for incorfie tax purposes 321 Debts deductible 700 Depletion and depreciation — Allowed on mines, oil and gas wells, etc 706 INDEX PAGE 34 CORPORATIONS— Continued. Paragraph No. Foreign Corporations — Continued. Depreciation allowed 702 Dividends deductible _..:.. 701 Dividends of — When all income derived from sources with U. S 295 Expenses deductible 694 Firms, corporations which are exempt from withholding at source 486 Interest on bonds not deductible 698 Interest on indebtedness 695 Inventories required 709 Losses deductible 699 New buildings, permanent improvements, betterments, etc., not deductible 703 Restoration of property not deductible 704 Returns — Domestic corporations — books in foreign country 692 Source of income „ 696 Taxes 697 Taxation of 691 Tax Withheld at Source Deductible — Deduction for losses not compensated by insurance.. 708 Foreign Coupons, Checks, Bills of Ezchang-e 354, 361 Fire Insurance — Premiums paid on , 138 Foreclosure — Sale on mortgage 181 Foreign Governments — Income from investments in U. S 86(5) Not taxable 538 Taxes paid to — deductible from total amount of income tax 149(a) Forms — In absence of forms a statement is accepted until sub- stituted by return on prescribed form 730 Prescribed by department must be used 729 Returns itemized on supplementary statement, Form 1031 715 To be furnished for reporting returns 712 Fraternal Beneficiary Societies — See "Exempt Corporations." Gifts- See also "Bonus." Property acquired by 15, 15(d), 86(3) To corporations 567 Good Will- Deduction for depreciation, not allowed 664 Gross Income — See "Income." Holding Companies — See "Exempt Corporations." Carrying charges 599 Returns of 505 Horticultural Orgranizations — See "Exempt Corporations." Humane Organization — See "Exempt Corporations." Import or Tariff Duties — Deductible as taxes 689 INDEX PAGE 35 C ORPORATIONS— Continued. Paragraph No. Zxnprovexnents — Cost of renewals 606 Depreciation 675 Leased property „ 617 New buildings, no deduction paid for same 620 Inoome — Accrued interest deductible from 775 Bad debt if collected 183 Bank discount ^ 574 Basis of tax 546 Bonuses and special payments 614 Books of account best guide to 776 Capital assets, sale of 575 Damages 569 Expenditures included as such 607 Fiscal year 547 Gross — Banks and financial institutions 550 Insurance companies 551 Gross income defined 558 Gross — Miscellaneous corporations 555 Gross computed by banks and other financial institu- tions 720 Gross computed by manufacturing corporations 721 Gross computed by mercantile corporations 722 Gross computed by other corporations 723 Interest — Brokers to include in gross income 585 Net Computed by New Corporations — Fiscal Year Returns of — How made 744 Computed on fiscal year basis 745, 746 Other 552 Patents, sale of 570 Personal property — sale of, on installments 553 Refunds of excess paid 762 Royalties from patents 573 Voluntary payments by stockholders 566 Zucomplete Corporations — Roturns by, liability for '. 493 Indebtedness — Lessee companies not to include that of lessor compa- nies 515 Individual Ownership — Private Banks — Association, held not to be 500 Information — To States — When 767 Regulations governing inspection 768 Information at the Source — Brokers — To make return of profits of customers when required (see page 86, line 51) 352 Dividends — Corporations to make return of dividends paid on -request of Commissioner (see page 86, line 41) 350(a) INDEX PAGE 36 CORPORATIONS— Continued. Paragraph No. Information at tlie Source-^Continued. Partnerships and corporations required to make return of income paid to another 350 Obligations of U. S. — return not required 315 Return of information of all payments of $1,000 or more made to another 354 Where corporation receiving payment is not the actual owner of income 345 Zustallment Payments — Default on, bad debts , 45 Income from sale of property paid by 44, 45 Loss from default of — how computed 45 Insurance- Business Insurance — See "Business Insurance." Insurance Companies — Deductions — Net addition to reserve funds 605 Policies covering life, health and accident 605 Definition of 490 Gross income of 551 Mutual Insurance — Premium deposits 605 Mutual Marine — Amount repaid to policyholders 605 Interest — Deductions — Bonds — See "Bonds," "Bonds — United States." Income from 15, 15(a) Obligations of State, Territory, County, Municipality, etc 86 ( 4 ) Return of information at source required of payer 350 Tax-free Bonds — See "Withholding at the Source." By corporation operating leased or purchased lines 556 On indebtedness 727 Accrued, deductible from income 775 Added where extension is granted 757 Allowable 678 Banks — On deposits or investment 611 Brokers — Gross income when receivetl by 585 Charged when abatement of taxes is claimed 765 Deposits 680 Different rates 681 Indebtedness as rental 679 Income from — Exchange of coupons for funding purposes 568 Paid by brokerage corporation 682 Paid or accrued 610 On exempt bonds, corporation 562 On indebtedness of leased property, assumed by lessee.... 515 Ikiventories — Merchandise 582 Securities 582 Investment Certificates — Status of „ 32, 310 INDEX PAGE 37 CORPORATIONS—Continued. Paragraph No. XTTigration Company — Assessment on stock of 173 Shrinkage in value of securities 172 Irrig-ation District — See also "Irrigation Corporations." Taxes assessed by 157 Xrrlg-atiou Bonds (District) — Losses Joint Stock Companies — Definition of 490, 491 £abor Org-anizations — See "Exempt Corporations." Iiandlord — Permanent improvements made by tenant 42 Taxes paid by tenant 143 Ziease — Permanent improvements made under 42 Ikeased l^ine Certificates — Income from considered to be dividends 32 Iieased Properties — See "Rent." I^essee (Corporation) — Rentals paid directly to bondholder or stockholder 31 ILiberty Bonds — See "Bonds — United States." z;icense — Annual list return : 35d Application for 355 Branch offices 356 Licensee to furnish list 357(a) Licensee to keep records 360 Penalty for failure to obtain 356 Required for collection of foreign coupons, checks, bills of exchange 354 Iiimited Partnerships — Associations, held to be 495 Iiiquidation — Of assets — how valued 25 lobbying* Expense 121 ]Losses — Deductions for — Bad debts 725 Corporation — . Irrigation Co. — Assessment on stock of 173 Shrinkage in value of securities 172 Inventory 634 Irrigation bonds „ 661 Judgments 633 Models, drawings, etc 667 Previous losses 644 Sustained 630 Removal of buildings ■.. 640 Retirement of bonds 643 When deductible 631 MannfactnrinsT — Cost of manufactured products 554 Manufacturing- Corporations — Gross income defined as taxable 721 CORPORATIONS— Continued. Paragraph No. Merchandise — Inventory of /.: 582 Mercantile Corporations — Gross income defined as taxable 722 Mines- See "Depreciation." Deductions — Allowed between the lessor and lessee 632 Value March 1, 1913 632 Miscellaneons Corporations — Gross income of 555 Mortg-ag-e — Foreclosure — Difference between purchase price and debt not deductible 181 Security — See "Bonds." Municipality — See also "State or Political Subdivision." Bonds of — Certificates of ownership not required 315 Bonds of — Exempt from tax 315 Bonds of Public Utility acquired by 316 Bonds — Public Utility acquired by — Income from not exempt 316 Taxes against local benefits — definition 158 Warrants of city — Face value to be accounted as income 78 Mutual Ditch and Irrigfation Companies — See "Exempt Corporations." Mutual Insurance Companies^ — Returns to be made by 501 Mutual or Co-operative Telephone Companies — See "Exempt Corporations." Mutual Saving's Banks — See "Exempt Corporations." Mutual Telephone Companies — Returns to be made by 501 Natural Deposits — Depletion allowance defined 198 to ?02 Name of Corporation — Charge in 518 New Building's — Erection of not deductible 641 Non-resident Alien Corporations — Bonds of — Tax on interest to be withheld and paid at source 318 Deductions: Depreciation 463 Mines, oil and gas well 464, 467 Interest on bank deposits — Tax on to be withheld 347 Notes — Tax on interest from to be withheld 348 Stock — Certificate to disclose ownership 447 Withholding provisions of law as applied to income 291(a), 291(b) Tax on dividends exempt from withholding 294 Withholding tax at source of income 478 When all tax not withheld 479 Oblig'ations of United States — See "Bonds — -United States." Of State— See "State or Political Subdivision." INDEX PAGE 39 CORPORATIONS— Continued. Paragraph Obsolescence- Models, drawings, etc 609 Physical property 670 When no depreciation is deducted 671 OU and Gas WeUs— See "Depreciation." Deductions — Allowed between the lessor and lessee 632 Value March 1, 1913 632 Other Corporations — Gross Income defined as taxable 723 Other Income — See "Income." Partnerships — Common-Law, not associations 496, 541 Liimited, held to be associations 495 Patents — Royalties from — See "Income." Sale of 570 Patents — Depreciation of 666 Sale of 672 Paying- Ag-ent — Bond Interest — Corporations niay appoint 335, 336 Returns of — See "Withholding at Source." Payment of Tax — Abatement of taxes (see "Abatement") 287 At the source — See "Withholding at the Source." Evasion of payment, penalty 285 Excess payment of tax — how treated '. 281 Failure to pay 286 Failure to Pay: No penalty in case of insane, deceased and insolvent persons 418 Instalment payments 253 • Payment optional 260 Receipt for to be given on request 279 Taxes withheld at source 304 When extension of time for filing return is granted 259 Penalties — Evasion of tax 285 Far failure to pay tax when due 764 For failure to file return 732 For failure to pay tax 731 For false or fraudulent return 734 For false statement of liability period ("Returns") 740 For giving information re Return.^ 742 For wilfully refusing to file returns 736 Paid by uncertified check , 763 Refund for failure to make return in 1913 739 Remitting for failure to file return 741 Returns properly mailed in time 750 Specific — For failure to pay or collect tax, make return or supply information 735 W^aived upon filing claim for abatement 765 Period of Return — Taxable period , 511 INDEX PAGE 40 CORPORATIONS— Continued. Paragraph No. Personal Property — See "Property." Personal Service Corporation — Definition 541(a) Not subject to tax as corporations 4i To make returns as partnerships 41 Philippine Islands — Taxes imposed by — See "Taxes" Obligations of — Interest on exempt 86 (4 > Philippine and Porto Bican Corporations — Tax on 492, 777 Plates (PubUshers)— Amount expended for an investment of capital 13 » Porto Bico— Obligations of — Interest on exempt 86(4) Taxes imposed by authority of — See "Taxes." Public Utilities- Income from — when not taxable 539 Purchased by Municipality — Indebtedness of 540 Prenxiam — Sale of capital stock 583 Premixuus — Paid on lives of officers or corporation 616 Private Banks — See "Bank." Associations, held to be 497, 499 Individual ownership of association, held not to be 500 Stockholders of, dividends of 498, 499 Profits — Undistributed, tax contingent on 11 Promissory Note of Corporation 311 Property — See also "Real Estate." Damages recovered by corporation 569 Depreciation of (court decision) 674 Exchange of - Exchange of corporation property for stock 571, 576 Income from sale of :. 43-45 Income from sale of, on installment plan 553 Losses in connection with — See "Losses." Method of determining value of 45 Obsolescence of 670 Permanent improvements made under lease or rental contract - 42 Title to — Cost of defending a capital investment 135 PubUc Utility- Bonds of acquired by municipality not exempt 316 Income from accruing to State, Territory, political sub- division and District of Columbia 86(6) Qualifications for Exemption 528 Bailroad Companies — Operating leased or purchased lines 556 Beal Estate — See also "Property." Depreciation of — See "Depreciation" 209 Foreclosure of mortgage on — See "Bad Debt." Income from sale of 558 Installment payment on — See "Installment Payments." INDEX PAGE 41 CORPORATIONS— Continued. Paragraph No. Real Estate — Continued. Permanent improvements made under lease or rental contract 42 Rebates — Loss from payment of under contract 166 Reclaimatioji — Taxes assessed for purposes of 15? Refund of Tax — ♦ Claims for 290(b) Refnnds — Income, war-profits or excess-profits paid in excess 762 Limitation of time for allowance of 762 Relig'ious Orgranizations — See "Exempt Corporations." Repairs — Cost of — How treated in computing "depreciation" 187 Reporting' at the Source- See "Information at the Source." Rent — Bond interest and dividends paid in lieu of rental.... 513, 557 Paid to stockholders of lessor 512 Rentals — Amounts expended for taxes or repairs by tenants 76, 143 Paid directly to bondholder or stockholder — Bad debts arising from unpaid ...., : 179 Permanent improvements made under lease or rental contract ,.. , 42 Return of information at the source required of payer.... 350 Sale of leasehold — deduction 139 Taxes paid by tenant to landlord 143 Tenant corporations making repairs 619 Reserves — Insurance, not deductible 629 Sinking Fund, for 563 Sinking Fund investments 564 Returns — By brokers 754 By domestic corporation on stock owned in foreign cor- poration 711 Close corporation 502 Consolidated 711 Consolidated returns by affiliated corporations 711 Copies of, Certified — Furnished by commissioner upon request of Attorney General 770 Corporations, all not exempt to make 501 Disclosure of — Penalty 771 Domestic corporations, doing business in foreign country 504 Domestic corporations with principal office in foreign country — where filed 6.07 Extension for filing 748 Failure to file — Penalty 732 Failure to receive 713 25% additional tax for failure to receive returns 714 False — Definition of 743 INDEX PAGE 42 CORPORATIONS— Continued. Paragraph No. Betums — Continued. False or fraudulent — Penalty 734 Fiscal year returns not acceptable 717 For fiscal year of new corporations — Forms for 712 Form of — Corporations 710 Insurance companies 710 Mutual insurance companies 710 Railroad corporations 710 Further extension for filing 749 Holding companies 505 How made 744 Incomplete corporations ^ 493 Independent for each taxable period 511 Instructions to corporations re annual net income 716 Itemized supplementary statement on Form 1031 715 "Last due date" defined 751 When falling on Sunday or legal holiday 752 Mutual telephone companies 501 Mutual insurance companies 501 New corporations, fiscal year basis 517 Net income computed on fiscal year basis 745 Of dividends 753 Acting for customers -. 754 On paid-up capital stock 718 Payments of $1,000 by individuals, corporations or part- nerships in any capacity 755 Penalty for false statement of liability period 740 Penalty for giving information of 742 Properly mailed in time not subject to penalty 750 Reasonable cause for failure to file 733 Remitting penalties for failure to file 741 Statement to be used in absence of prescribed forms 730 Specific penalty for failure to make return 735 Penalty 736 Subsidiary companies 506 Tentative 508 To be made by receivers, trustees or assignees of cor- porations 728 To be made on forms prescribed 729 Upon which tax has been determined are public records.. 766 Verifying accuracy of 737 Wilful refusal to file — Royalty — Income from taxable = 77 Salary — Employee — Paid after death, not deductible 625 Foreign employe — Not subject to withholding at source.... 361 Scientific Org'anizations — See "Exempt Corporations." Securities — Assessments on — - - .- 122 Book values — Shrinkage i'a 203 Commissions paid for purchase and sale of 125 Dealers in 203,205 INDEX PAGE 43 CORPORATIONS— Continued. Paragrapn No. Securities — Continued. Exempt securities — Income from, how treated 96 Inventory of 582 Investment certificates 31u Issued by War Finance Corporation, exempt 12(b), 86(4) Issued under Federal Farm Loan Act 86(4) Owned by foreign governments 86(5) Leased line or stock trust certificates — taxable status 32 Promissory note of corporation 311 See also "Stocks," "Bonds," "Bonds — United States." Shrinkage in value of — Written off by authority of State officials 581 Value reduced at direction of Comptroller of Currency.... 170 Sinkingr Fund — Investments by corporations „ 564 Reserves set aside by corporations 563 State or Political Subdivision — Definition 87 Bonds of — Certificate of ownership not required 315 Bonds of — Interest from exempt : 314 Contractor with — Status of 70 Expense incurred in earning income not allowable de- duction 101 Income derived from public utility 86(7) Obligations of — Definition 88 Obligations of — Interest from exempt 85(4) Obligations of — Interest on exempt from tax 86(4) Officer or employee of — definition 70 Taxes imposed by — See "Taxes." Warrants issued by 78 Statistics — Publication of — Commissioner shall annually issue 772 Stock — Treasury stock, when taxable 566 Stock Dividend — See "Dividends." Stockholders — Private banks 498, 499 Rentals paid by lessee directly to 31 Stock (Securities) — Bonus in common stock 51 Dividends on — See "Dividends." Profit from sale of — how treated 72 Profit from sale of lots purchased at different times 72 Profit from sale of stock acquired by gift 75 "Rights" (subscription) income from 74 Stock Trust Certificates — Income from considered as dividends 32 Subsidiary Companies — Earnings or dividends from, not deductible 560 Returns by 506 Supplementary Statements — Publicity of — prohibited — same status as returns 769 Tariff- See "Customs Duties." INDEX PAGE 44 CORPORATIONS— Continued. No. Paragraph Taxes — Allowable 683 Allowable deduction 612 Are not to be re-collected when once paid 738 As Expense or Deduction: Paid by tenant as part of rent 76 Assessment and payment of — Installment payments 756 Bank stock taxes 687 Basis of 546 Corporations, imposed on 488 Custom duties — not taxes — deductible expenses 688 Deductible from income 147 By beneficiary of an estate 149(a) By member of partnership 149(a) Porto Rico and Philippine Islands — Imposed by authority of 149 State, county and municipal taxes....'. 150 United States — Imposed by authority of 149 Deductible as Rental: Paid by tenant to landlord 143 Deductible from Total Amount of Tax: Income, war profits and excess-profits taxes imposed by U. S. Possessions and foreign countries 149 Excess profits tax credit 686 Failure to pay — Penalty 731 Falsely or fraudulently returned 760 Fiscal year basis 547 Foreign Taxes 146(a), 149 to 152 Foreign taxes — (paid to foreign countries) 149(b) Import or tariff duties :. 689 Imposed by United States Gov't — Read 11416(a) and Us 147 to 152. Income taxes not deductible 133 Limitation of time for filing refund claim 758(b) I-iimit of time for assessing tax 760 Local benefits 685 Made in single payment 758 Not Deductible from Income: Imposed by Philippine Islands, Porto Rico 149 Income, war-profits and excess-profits taxes 14 On bonds containing a tax-free clause 759 Paid by uncertified check not honored by bank — Liability for 763 Paid in behalf of stockholder by bank on capital stock allowable deduction 37, 214 Paid to foreign country deductible from total amount of income tax 149 (b) Past due voluntarily paid 761 Payments where extension is granted — Interest added 757 Payment at source on income to non-resident aliens 759 Penalty for failure to pay when due 764 Philippine and Porto Rican corporations 492, 777 Philippine Islands: Taxes imposed by 146(a), 149 to 152 Refund of penalties for failure to make return in 1913.... 739 INDEX PAGE 45 CORPORATIONS— Continued. No. Paragraph Taxes — Continued. Refund under any previous or the present Act 758(a) Specific penalty for failure to pay or collect tax 735 State or Political Sub-division: Taxes imposed by 150 Tax-free bonds, taxes not deductible 684 Tax-Free Covenant — See "Bonds." U. S. Gov't — Taxes imposed by — Read 11146(a) and !Isl47 to 152. When abatement is claimed — Penalty relapses and interest is charged 765 Taxable Period — Definition of 489 Taxable Year — Definition of 489 Tax-Free Bonds — Taxes on — not deductible 684 Tenant — Permanent improvement made by 42 Repairs made by, as part of rent 76 Taxes paid by as part of rent 76, 143 Tentative Returns 508 Territory — Interest from obligations of 86(d) Timber — Depreciation and depletion allowed 198 to 202 Loss by flre of standing timber 165 Timber l^ands — Regulations governing 673 Town — See "Municipality." Trade Marks and Trade Brands — Deduction for depreciation not allowed 663 Trading Stamps — Redemption of 615 Treasury Decisions — Effective date of 381 Trust Companies — See "Banks." Gross income of 550 trndistribnted Profits — See "Profits." United States — Bonds of — See "Bonds — United States." TT. S. Government — Bonds of — See "Bonds — United States." Government officers and employes Compensation not paild in money 95 Taxable status of income 96 Liberty Bonds — See "Bonds — United States." Securities issued by War Finance Corporation — See "Securities." Taxes deductible from income 149 Taxes imposed by authority of — See "Taxes." United States Possessions — Citizens of 773 War Pinance Corporation — Securities issued by, exempt 86(4), 12(b) TTvrmrv T>Amr ac CORPORATIONS— Continued. No. Paragraph War-Profits Tax Amount paid as not deductible 149, 150 Warrants of City or Town 78 Where Filed — Returns by — Domestic corporations having principal office in foreign country 507 Withholding- Agrent — See "Withholding at the Source." Withholding: at the Source — Bond — Certificates of ownership — See "Certificates of Ownership." Bond Interest — Tax on: Amount of tax to be withheld 308 Bonds containing tax-free covenant 309 Bonds without tax-free covenant — Payment cannot be made at source 309(e) Citizen or Resident Corporation — May file certificate of exemption 309 (a) Exempt organization — Certificates to be filed 313 No withholding when exemption claimed 309(b) Of 2% to be deducted from income of citizen or resident or non-resident alien corporation 309 Owners not known to withholding agent — Commis- sioner may authorize deduction 309 Tax-free Bonds — Important distinction for income tax purposes 309 (f ) Tax-free bonds — issued with and without tax-free covenant — Important distinction 309(e), 309(f) Varying policy of corporations 309 Tax-free bonds only 308, 309 Tax-free covenant — Contract between corporation and bondholder 309 (c) Tax withheld only a partial tax 309(d) Exempt organizations subject to provisions of law 293 Fiduciaries 404 Foreign corporations 291 (b) Non-resident alien corporations 291(a) Non-resident alien corporations — Tax on dividends not to be withheld 294 Non-resident Alien Corporation: Interest from bank deposits — Tax on 347 Interest from notes 348, 349 Payment of tax withheld : 304 Provisions of the act, as applied to citizen, resident and non-resident alien corporations 291 Also see Law, page 69, lines 27-48. Returns: Of information at the source. See "Information at the Source." Stock and Treasurry Stock — Withholding Agent: Annual return of 305 Bond interest— Non-resident alien corporations 312 Corporation may appoint paying agent 335, 336 Defined 317, 292 Monthly Return of 306 INDEX PAGE 47 CORPORATIONS-Continued. No. Paragraph Withholding* at the Souroe-— Non-resident alien corporations 318 Paying agents 317 Payments of tax withheld 304 Penalty for divulging information 306 Returns of: Annual return 305, 344 Monthly list 304, 306, 344 Monthly List — Duplicates to be filed 338 Monthly list — ^Where filed 337, 344 Penalty for divulging information 307 Salary- of foreign employe exempt 361 INDEX PAGE 48 War-Profits and Excess-Profits Tax. Reference is made to Faragrraph Numbers and NOT to pages. Paragraph No. Accoiuiting- — Methods of application to invested capital adjustments.... 863 Accounts Receivable — Tangible property 848 Act of 1917— "Excess Profits Tax Primer," published for the guidance of those who may be required to file amended returns for the year 1917 See pages 1347 to 1364 Additions to Capital — Allowable 904 Amortization — Improper allowance for 862 Assets — Admissible — Law, page 94, line 52. Tangible 902 Intangible 905 Inadmissible — Law, page 94, lire 40. Tangible 923 Intangible 905 Averag'e Adjustments of Capital — Illustration 914 Balance Sheets 868 to 880 Illustrations — Capital adjustments 864 to 897 Must conform to adjustments of capital 912 Bills Receivable- Tangible property 848 Bonds — Tangible property - 848 Calendar Year — Returns, due date of 788 Capital Invested — Defined Z 840 Dividends paid, allocated 894, 896 Addition of reserves for taxes 886 Adjustments during the year 883 Allowance for depletion and obsolescence in connection with 840 Average adjustments (illustration) 914 Averaged for year by months 841 Borrowed capital excluded 844 Capital stock and surplus 882 Certain exempt securities may be included 845-846 Corporations at disadvantage due to manner of account- ing 859 Donated stock 890 Exceptional cases where capital cannot be satisfactorily determined 854, 855 Expense in securing data on foreign corporations in con- nection with invested capital 857 INDEX PAGE 49. WAR-PROFITS AND EXCESS-PROFITS TAX— Continued. Paragri^)b No. Capital Invested — Continued. Foreign corporations (proportion) .» 849 Inflated value of good will » .— . 891 Items not allowed to be included 842 Mixed aggregate of tangible and Intangible property in connection with 858 Organization expenses 889 Overvaluation of stock 892 Patents and copyrights 903 Pre-war period 853 Reserves for bad debts .....885, 888 Reserves for improvements and contingencies 887 Reserves subject to careful scrutiny 884 Sinking fund reserve 897 Stock issued for intangible assets 900 Stock of foreign corporations 847 Stocks, bonds etc., not to be included 843 Tangible and intangible assets defined 848 Taxes paid under 1917 Act, relation to 924 Tax free securities and profits from tradings 846 Value of intangible assets 901 Where capital is disproportionate by comparison with representative corporations 860 Copyrisrhts, Valuation — Intangible assets, valuation of 901 Corporations — Adjustment due to improper valuation 899 Balance sheets illustrated '. 869 Capital adjustments 882 to 897 Capital, pre-war period 853 Denied right of comparison 898 Exempt corporations 792 Income from gold mining 792 Net income less than $3,000 792 Same corporations exempt as under Title II. (Cor- poration Income Tax) 792 Foreign corporations 791, 849 Limitation of tax 806 Method of calculating tax .*.. 797 Organized prior to July 1, 1919 852 Rates of tax 794 Rate per cent, of tax 802 Reorganized after Jan. 1, 1911 850 Reorganized after March 3, 1917 851 Subject to tax 790 When credit exceeds 20% of capital (illustration) 803 Credits- Excess profits 827 Illustration 814 War Profits Credit — How determined 828 Alternative method 813 Defective AooonntinsT — Where capital cannot be accurately determined 856 INDEX PAGE 50. WAR-PROFITS AND EXCESS-PROFITS TAX— Continued. Paragraph No. Definitions 780 Dividends 785 Fiscal year 782 Paid or accrued 784 Personal Service Corporation ...783 Pre-war period 786 Taxable year 1 781 Dividends — Allocation of 894 Received from foreign corporations 835 Excess Profits — Excess profits credit 827 Method of computation 807 Rates of tax 794 When credit exceeds 20% of capital 803 Fiscal Year — Amount paid under 1917 Act a credit 916 Computations 915 Partnership or personal service corporation 918 Proportionate amount payable 917 Refunds of taxes paid 919 Returns, due date of 789 Foreign Corporations — Invested capital of 847 Not entitled to exemption 791 Stock of, in relation to invested capital 814 Gold Mining- — Income derived from (exempt) 792 G-ovemznent Contracts — 50% or more from -. 831 ninstrations — Balance sheets showing capital adjustments ....868 to 880 Limitation of tax 806 Methods of calculating 797 When excess profits credit exceeds 20% of invested capital 803 Intangible Property 905 to 908 Defined 848 Stock issued for 900 Valuation of 901 As admissible or inadmissible assets — Law, page 94, line 40. Invested Capital — See "Capital" for details. Trade or business having 826 I^easeliolds — Tangible property 848 I^imitation of Tax — From sale of mines 921 Illustration 815 Mines- Limit of tax from sale of 921 Net Income — Average for pre-war period 839 Classification of 793 For calendar years 1911-1912 836 For fiscal year 1913 837 For taxable year 838 INDEX PAGE 51. WAR-PROFITS AND EXCESS-PROFITS TAX— Continued. Paragraph No. Notes and Other Evidence of Indebtedness — Tangible property 848 Paid or Accrued — Definition of 785 Partnerships — Credit for taxes 916 Fiscal year basis 918 Refunds of taxes paid under 1917 Act 919 Patents and Copyrifirhts — Intangible Assets — Valuation of 901 Pre-war Period — Corporation not in existence during 831 No net income for 830 War profits credit 831 Property — Intangible 848 Limitation on value of intangible 901 Limitation on value of tangible 923 Returns 787 Due date, calendar year 788 Due date, fiscal year 789 Sinking Pnnd Reserve—- Segregation of surplus 897 Stock- Constitutes tangible property 848 Issued for tangible property, or returned as a gift 902 Surplus — Reconstruction of accounts 903 Tangible Property — Bills and accounts receivable 848 Bonds 848 Construction oi term 848 Excess value of 902, 911 Leaseholds 848 Limitation on value of 923 Mixed aggregate of tangible a©d intangible 833 Notes, etc 848 Stock or shares issued for 923 Stocks _ 848 Tax, Rates of-— Comparison with similar corporations 819 Computation for fiscal year 822 Credit for 1917 taxes 825 Determined by commissioner 820 Due to abnormal conditions 834 Foreign corporation 818 Limitation of 805 Limit of, in connection with mines 921 Method of calculating j* 794 Rate per cent on $500,000 „ 797 Rates for 1919 and subsequent years 922 When 50% or more of net income, conditions 821 When not satisfactorily determined 817 Taz-Pree Securities — When income from, consists partly of profits from trad- ings in 846 INDEX PAGE Sa. WAR-PROFITS AND EXCESS-PROFITS TAX— Continued. Paragraph No. Undivided Surplus — Employed in business 910 Reconstruction of accounts 903 Values — Tangible property, other than cash paid in for stock or shares 923 Excess value of tangible property 902 War-Profits Credit — How computed 828 Alternative method 813 Foreign Corporations 814 INDEX PAGE 53. Estate Tax. Section Page Schedule of Tax Rates 401 100 Estate^ Gross estate — Value of, how determined 402 101 Net estate — Value of, how determined : 402 102 Exemption allowed 102 Executor — Definition 400 100 Notice of qualification 404 104 Statement by 404 104 Penalties 408 105 Returns 404 20 Failure to file 405 104 Where no administration is granted 405 104 False return 410 106 Payment of Tax — When due 406 105 When paid 407 105 Where amount of tax cannot be determined 407 105 Receipts for 407 105 Failure to pay 408 105 INDEX PAGE 55. Transportation and Other Facilities and On Insurance. Section Page Transportation — Freight 500 (a) 107 502 109 Express 500 (b) 107 502 109 Passenger 500 (c) 107 Parlor car and sleeping car 500 (d) 108 Conditional tax on mileage books and tickets... 501 (b) 108 Taxes on : Who pays 501 (a) 108 How applied 50J (c) 109 502 109 Payee to collect tax 502 109 Payee to make returns and pay tax 502 109 Refund of payment 502 110 Returns 502 110> Payment of tax — when due -502 110 Oil by pipe line 500 (e) 108 501 (d) 109 502 109 Teleg'raph and Telephone — - Telegraph messages 500 (f) 108 Telegraph leased wires 500 (g) 108 Telephone messages 500 (f) 108 Telephone leased wires 500 (g) 108 Cable messages 500 (f) 108 Insurance 503 110 Life insurance 503 (a) 110 Marine, inland and fire insurance 110 Casualty insurance _ 503 (b), 503 (c) 110 Exempt insurance 503 (d) 110 Insurance Co. to collect tax — Tax assessed against insurer 503 110 Insurance Co. to make return and pay tax 504 110 Payment of tax — when due 504 110 ywrnrv -DAnir rfr Treasury Decisions. The following is an index of Treasury Decisions, Court De- cisions and other Income and Excess Profits Tax data promul- gated under the Act of September 8th, 1916, as amended, and the Act of October 3rd, 1917, which have been issued since the pub- lication of the Standard Manual of Income Tax for 1918. Such of these decisions as apply to the existing law have been digested and embodied in the Manual for 1919. Others have no direct bearing on the Revenue Act of 1918, and are published merely for the guidance and benefit of those who may be required to file amended returns for the year 1917 and also for information where the subject matter pertains to the Revenue Act of 1918. Page T. D. 2649 1203 T. D. T. D. 2652 1204 T. D. T. D. 2654 1204 T. D. T. D. 2659 1205 T. D. T. D. 2660 1207 T. D. T. D. 2661 1208 T. D. T. D. 2662 1210 T. D. T. D. 2663 1212 T. D. T. D. 2665 1213 T. D. T. D. 2666 1215 T. D. T. D. 2668 - 1218 T. D. T. D. 2670 1222 T. D. T. D. 2671 1224 T. D. T. D. 2672 1224 T. D. T. D. 2673 1225 T. D. T. D. 2674 1225 T. D. T. D. 2677 * 1226 T. D. T. D. 2678 1226 T. D. T. D. 2679 1227 T. D. T. D. 2683 1228 T. D. T. D. 2686 - 1229 T. D. T. D. 2687 1231 T. D. T. D. 2688 1232 T. D. T. D. 2689 1233 T. D. T. D. 2691- 1235 T. D. T. D. 2692 1235 T. D. T. D. 2693 1237 T. D. T. D. 2695 1238 T. D. T. D. 2696 - 1238 T. D. T. D. 2697 1241 T. D. T. D. 2698 1245 T. D. T. D .2700 1246 T. D. T. D. 2702 1247 T. D. T. D. 2705 1248 T. D. T. D. 2706 1249 T. D. T. D. 2707 1250 T. D. Page 2708 1251 2709 1252 2711 1253 2715 1254 2716 "...1255 2720 1257 2721 1264 2722 1269 2723 1272 2724 1278 2725 1282 2726 - 1283 2729 1286 2730 ....1291 2731 1297 2732 1302 2733 1304 2734 1308 2735 1310 2736 1310 2737 1315 2740 1316 2744 1319 2747 1319 2754 1320 2755 1321 2756 1321 2759 1323 2762 1326 2763 1328 2770 1329 2771 1330 2772 1331 2773 1332 2778 1333 2783 ....1335 Standard Manual of the Income Tax On the preceding pages will be found a digest of the new Revenue Law. That digest was prepared to familiarize the user of this book with the general provisions of the Act, par- ticularly the changes therein, and to serve as a groundwork for utilizing the more detailed information which follows. INDIVIDUALS Normal and Additional Tax THE NORMAL TAX. ^ 1— Who and What is Taxable. Title II of the Revenue Act of 1918 imposes a normal tax for the year 1918 as follows : If 2 — Citizens and Residents. (a) 6 per centum on the first $4,000 of net income in ex- cess of the credits allowed ($1,000 or $2,000), received in the preceding taxable year from all sources by an individual, a citizen or resident of the United States, and 12 per centum on all net income in excess of the first $4,000. ^ 3 — Non-Resident Aliens. (b) 12 per centum on the entire net income in excess of the credits allowed, received in the preceding taxable year from all sources within the United States by every indi- vidual, a non-resident alien, including interest on bonds, notes or other interest-bearing obligations of residents, cor- porate or otherwise. 177 INDIVIDUALS-^Continued NORMAL TAX Ti 4 — Naturalized Citizens Residing Abroad. Naturalized citizens who have brought upon themselves the presumption of expatriation, under provisions of Section 2 of the Act of March 2, 1907, by protracted residence abroad, may overcome such presumption only upon present- ing satisfactory evidence, etc. — Letter of Secretary Bryan. *[ 5— Citizenship. Determination of the State Department of right to regis- try is not conclusive upon the Treasury in fixing citizenship for income tax purposes. The Treasury Department, there- fore, holds that native and naturalized status remains unless changed by affirmative action or forfeited by overt act. |[ 6 — Income Tax Laws of Other Countries. American citizens, whether residing at home or abroad, and non-resident aliens, receiving incomes from property owned and from business, trade or profession carried on within the United States, are not reheved from tax liability by being subject to the income tax laws of other countries. ff 7— ADDITIONAL OR SURTAX. The additional graduated tax rates and amounts of income subject thereto imposed in accordance with the provisions of the Revenue Act of 1918, on net incomes of more than $5,000 for the year 1918, are as follows : Amount Net Income Taxable A B C $5,000 to $6,000 $1,000 6,000 to 8,000 2,000 8,000 to 10,000 2,000 10,000 to 12,000 2,000 12,000 to 14,000 2,000 14,000 to 16,000 2,000 16,000 to 18,000 2,000 18,000 to 20,000 2,000 20,000 to 22,000 2,000 22,000 to 24,000 2,000 24,000 to 26,000 2,000 26,000 to 28,000 2,000 28,000 to 30,000 2,000 178 Tax on Taxed Am'tAdd'l Amt. in At Tax Column B JD E F 1% $10 $10 2% 40 50 3% 60 110 4% 80 190 5% 100 290 6% 120 410 7% 140 550 8% 160 710 9rcf 180 890 10% 200 1,090 11% 220 1,310 12% 240 1,550 13% 260 1,810 INDIVIDUALS— Continued ADDITIONAL OR SURTAX Tax on Amount Taxed Am't Add'l Amt. in Net Income Taxable At Tax Column B A B C D E F 30,000 to 32,000 2,000 14% $280 $2,090 32,000 to 34,000 2,000 15% 300 2,390 34,000 to 36,000 2,000 16% 320 2,710 36,000 to 38,000 2,000 17% 340 3,050 38,000 to 40,000 2,000 18% 360 3,410 40,000 to 42,000 2,000 19% 380 3,790 42,000 to 44,000 2,000 20% 400 4,190 44,000 to 46,000 2,000 21% 420 4,610 46,000 to 48,000 2,000 22% 440 5,050 48,000 to 50,000 2,000 23% 460 5,510 50,000 to 52,000 2,000 24% 480 5,990 52,000 to 54,000 2,000 25% 500 6,490 54,000 to 56,000 2,000 26% 520 7,010 56,000 to 58,000 2,000 27% 540 7,550 58,000 to 60,000 2,000 28% 560 8,110 60,000 to 62,000 2,000 29% 580 8,690 62,000 to 64,000 2,000 30% 600 9,290 64,000 to 66,000 2,000 31% 620 9,910 66,000 to 68,000 2,000 32% 640 10,550 68,000 to 70,000 2,000 33% 660 11,210 70,000 to 72,000 2,000 34% 680 11,890 72,000 to 74,000 2,000 35% 700 12,590 74,000 to 76,000 ^ 2,000 36% 720 13,310 76,000 to 78,000 2,000 37% 740 14,050 78,000 to 80,000 2,000 38% 760 14,810 80,000 to 82,000 2,000 39% 780 15,590 82,000 to 84,000 2,000 40% 800 16,390 84,000 to 86,000 2,000 41% 820 17,210 86,000 to 88,000 2,000 42% 840 18,050 88,000 to 90,000 2,000 43% 860 18,910 90,000 to 92,000 2,000 44% 880 19,790 92,000 to 94,000 2,000 45% 900 20,690 94,000 to 96,000 2,000 46% 920 21,610 96,000 to 98,000 2,000 47% 940 22,550 98,000 to 100,000 2,000 48% 960 23,510 100,000 to 150,000 50,000 52% 26,000 49,510 150,000 to 200,000 50,000 56% 28,000 77,510 200,000 to 300,000 100,000 60% 60,000 137,510 300,000 to 500,000 200,000 63% 126,000 263,510 500,000 to 1,000,000 500,000 64% 320,000 583,510 Exceeding 1,000,000 65% An individual who is single with a net income of $5, 100,000 will be obliged to pay the normal and additional tax 179 INDIVIDUALS— Continued ADDITIONAL OR SURTAX calculated on the amounts in accordance with the following methods : Net *$5,100,000 Exemption 1,000 t$5,099,000 *Amt. on which additional tax is calculated. fAmt. on which normal tax is calculated. 1i 8— CALCULATION OF ADDITIONAL TAX. Amt. Taxed at of Tax Total $5,000 None None 1,000 1% $10 2,000 2% 40 ' 2,000 3% 60 2,000 4% 80 2,000 5% 100 2,000 6% 120 2,000 7% 140 2,000 8% 160 2,000 9% 180 2,000 10% 200 2,000 11% 220 2,000 12% 240 2,000 13% 260 2,000 14% 280 2,000 15% 300 2,000 16% 320 2,000 17% 340 2,000 18% 360 2,000 19% 380 2,000 20% 400 2,000 21% 420 2,000 22% 4€0 2,000 23% 460 2,000 24% 480 2,000 25% 500 2,000 26% 520 2,000 27% 540 2,000 28% 560 2,000 29% 580 2,000 30% 600 2,000 31% 620 2,000 32% 640 2,000 33% 660 180 INDIVIDUALS— Continued ADDITIONAL OR SURTAX $2,000 2,000 2,000 2,000 2,000 Ji,000 2,000 2,000 2,000 2,000 2,000 2,000 2,000 2,000 2,000 50,000 50,000 100,000 200,000 500,000 4,100,000 $5,100,000 ted at of Tax Total 34% $680 35% 700 36% 720 37% 740 38% 70U 39% 380 40% 800 41% 820 42% 840 43% 860 44% 880 45% 900 46% 92a 47% 940 48% 960 52% 26,000 56% 28,000 60% 60,000 63% 126,000 64% 320,000 65% 2,665,000 $3,248,510 K 9— CALCULATION OF NORMAL TAX. $5,099,000 Amount subject to normal tax. 4,000 At 6% $240 $5,095,000 Balance at 12%.__ 611,400 $611,640 Total normal tax. 3,248,510 Additional tax. $3,860,150 Total tax due. In the above example, for the purposes of the normal tax only, he would be allowed to deduct from his net income all amounts received as dividends on capital stock or from the net earnings of corporations, the amount received as in- terest from obligations of the United States and bonds is- sued by the War Finance Corporation, plus the $1,000 or 181 INDIVIDUALS— Continued ADDITIONAL OR SURTAX $2,000 exemption allowed according to the marital status of the individual, in addition to $200 for each dependent if under 18 years of age, or incapable of self-support because mentally or physically defective. \\ 1 — Income from Dividends to Be Included. For the purpose of additional tax, there shall be in- cluded as income, the income derived from dividends on the capital stock or from the net earnings of any corporation, joint-stock company, or association, or insurance company, except that in the case of non-resident aliens such income derived from sources without the United States shall not be included. 1111 — Tax Contingent on Undistributed Profits. Section 220 of the Act provides that if any corporation, however created or organized, if formed or availed of for the purpose of preventing the imposition of the surtax upon its stockholders or members through the medium of per- mitting its gains and profits to accumulate beyond the reasonable needs of the business instead of being divided or distributed, such corporation shall not be subject to the cor- poration income tax imposed by Section 230, but that the stockholders or members thereof shall be subject to taxa- tion in the same manner as partners. Such corporations are, however, subject to the war-profits and excess-profits tax imposed by Title III of the Revenue Act of 1918 and the amount of that tax shall be deducted from the net income before computing the proportionate share of each stock- holder or member. In other words, if the Commissioner of Internal Revenue decides that a corporation has allowed its profits to accumu- late beyond the reasonable needs of the business and for the sole purpose of allowing the individual stockholder to escape payment of the surtax on their individual incomes, the profits, after deducting the war-profits and excess-profits tax imposed by Title III of the Revenue Act of 1918, which have been so accumulated shall be assigned to the individual stockholders in proportion to their stockholdings and shall be taxable to them, not as dividends received from corpora- 182 INDIVIDUALS— Continued INCOME—Net Income tions, but as a distribution of partnership profits and sub- ject to both the normal tax of 6 and 12 per cent, and the additional taxes. With respect to a similar provision in the Act of Oct. 3, 1913 (old law), Treasury Decision 2135 held that the law imposes no duty on the taxpayer to ascertain his distribu- tive interest in the undivided surplus of corporations for the purpose of making return of the amount, in addition to divi- dends declared on his stock, unless the Secretary of the Treasury has certified that, in his opinion, such accumula- tion is unreasonable for the purpose of business. INCOME. NET INCOME. ^ 12 — Definition of Net Income. The net or taxable income of an individual is his gross in- come, i. e., his total gains, profits and income derived from every source, less the deductions allowed. ^13 — Normal Tax — Upon What Computed. In computing the taxable income for the purposes of the normal tax there shall be deducted from the net income as above ascertained : (a) Dividends on the stock or from the net earnings of corporations, joint-stock companies, or associations, or in- surance companies which are taxable under the law. See Law, page 73, Hhe 54, page 74, line 18. (b) The amount received as interest upon obligations of the United States, and bonds issued by the War Finance Corporation, which is included in gross income. See tf 29. (c) The personal exemption of $1,000 or $2,000, as the case may be, and $200 for each dependent. See If 21 6, 21 7. U 1 4 — Net Income — How Computed. An individual shall compute net income upon the basis of his annual accounting period (fiscal year or calendar year, as the case may be) in accordance with the method of 183 INDIVIDUALS— Continued INCOME— Gross Income accounting regularly employed in keeping his books, but if no such method of accounting has been employed or if it does not clearly reflect the income, the computation shall be made upon such basis and in such manner as in the opinion of the Commissioner does clearly reflect the income. If the taxpayer's annual accounting period is other than a fiscal year or if the taxpayer has no annual accounting period or does not keep books, the net income shall be computed on the basis of the calendar year. If a taxpayer changes his accounting period from fiscal year to calendar year, from calendar year to fiscal year, or from one fiscal year to an- other, the net income shall, with the approval of the Com- missioner, be computed on the basis of such new account- ing period, subject to the provisions of Section 226. See H 247 to 251. 1115— GROSS INCOME. The gross income of a taxable person includes : Gains, profits and income derived from — (a) Salaries, wages, or compensation for personal service of whatever kind and in whatever form paid. (Including in the case of the President of the United States, the judges of the Supreme and inferior courts of the United States, and all other officers and employes, whether elected or ap- pointed, of the United States, Alaska, Hawaii, or any politi- cal subdivision thereof, or the District of Columbia, the compensation received as such.) (b) Professions, vocations, businesses, trade, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of, or interest in, real or personal property. (c) From interest, rent, dividends, securities, or the trans- action of any business carried on for gain or profit, or gains or profits, and income derived from any source whatever. (d) Gains or profits and income derived from any source whatever, including the income from, but not the value of, property acquired by gift, bequest, devise or descent. If the property so acquired (by gift, etc.) is subsequently sold at a price greater than the fair market value on the date 184 INDIVIDUALS— Continued INCOME— Gross Income received, or the fair market value on March 1, 1913, if re- ceived prior to that date, the gain in value is held to be in- come and subject to tax under the provisions of the Federal income tax law. ^ 1 6 — Legacies — Bequests. The general policy of the law and rule of interpretation require that legacies in all cases, unless clearly inconsistent with the intention of the testator, should be held to be vested rather than contingent. The legal definition of "vested" is any property interest whether actually in possession or not that is not subject to contingency or to conditions unperformed. Where there is a vested interest, the income from such interest, if undistributed, is taxable in the hands of the fidu- ciary ; if distributed, it is taxable in the hands of the bene- ficiaries, and the fiduciary is required to make return, for information purposes, if the amount distributed to any one beneficiary during the year 1918 equalled or exceeded $1,000 or $2,000, according to the marital status of the individual, estate or trust for which he acts. Tf 1 7 — Time of Accrual of Income. Fixed and determinable income, becoming due and pay- able since February 28, 1913, such as that derived from salaries, wages, compensation, etc., or from interest on bonds, should be returned as income for the year (calendar or fiscal year) in which such income is received. Thus — (Return made on basis of calendar year.) (a) Coupons which fell due prior to Jan. 1, 1918, but which were not paid until that date or later ; (b) Income received by trustees prior to Jan. 1, 1918, but not paid over to the beneficiary until that date or later ; (c) Dividends declared prior to Jan. 1, 1918, but not paid until that date or later ; (d) Salary or wages earned in 1917, but not paid until Jan. 1, 1918, or later — all should be returned as income for the year ended Dec. 31, 1918. 185 INDIVIDUALS— Continued INCOME— Dividends U 1 8 — Receipt Basis. Actual receipt is a reduction to possession. Constructive receipt is where income is credited to or made available to recipients and is to be reported as income; as credit to ac- count of recipients of savings-bank interest, etc. In the case of compensation for service renavired, where no determination of compensation is had until the com- pletion of the service, the amount received in consideration of the service is income to be accounted for as for the cal- endar year of its receipt. Where the service and payment period is divided by the end of the taxable year, the compensation for the period so divided at the end of the year will be accounted for as income for the year in which payment is actually received. Where the service is compensated by fee, or is of such nature that no part of the fee or compensation becomes due until the completion of the service, the entire amount rceived should be income to be accounted for as for the year of receipt. A person having a salary by the year ahd in addition commissions on sales, the salary to be paid at the time commissions are determined, and the determination of com- missions is in the succeeding calendar year, the entire amount of salary and commissions should be accounted for as income of the calendar year of receipt. — Art. 4, Reg. 33, Revised. DIVIDENDS. ^ 1 9 — Income from Dividends. Income from dividends, while not subject to normal tax, must be included in every return. See jf 29. The term "dividend" means any distribution made by a corporation other than a personal service corporation to its shareholders or members whether in cash or in other prop- erty or in stock of the corporation out of its earnings or profits accumulated since February 28th, 1913 ; or any such distribution made by a personal service corporation out of its earnings or profits accumulated since February 28th, 1913, and prior to January 1st, 1918. Any distribution 186 INDIVIDUALS— Continued INCOME— Dividends shall be deemed to have been made from earnings or profits unless all earnings and profits have first been distributed. Any distribution made in the year 1918 or subsequent years shall be deemed to have been made from earnings or profits accumulated since Feb. 28, 1913, or, in the case of a personal service corporation, from the most recently accumulated earnings or profits ; but any earnings or profits accumulated prior to March 1, 1913, may be distributed in stock divi- dends or otherwise, exempt from the tax, after the earnings and profits accumulated since Feb. 28, 1913, have been distributed. (The first income tax act became effective March 1, 1913.) ]f 20 — Cash Dividends. Cash dividends or their equivalent paid from the net earnings or established surplus or undivided profits of cor- porations, accumulated since Feb. 28, 1913, constitute tax- able income in the hands of shareholders or beneficiaries when received, and should be included in the return when the total net income of any individual is in excess of $1,000 or $2,000, according to the marital status of the taxpayer, inclusive of such dividends, and the additional tax should be paid thereon at the rates prescribed by law for the year in which the dividends were received. ^ 21— Stock Dividends. There have been two court decisions in connection with stock dividends which may ultimately have an important bearing on the present law. The case of Towne vs. Eisner on January 7th, 1918, in which the United States Supreme Court ruled that stock dividends paid during the years 1913, 1914 and 1915 were not taxable income; and the decision handed down by Judge Mayer of the United States District Court on January 23rd, 1919, in which it waB held that stock dividends were not taxable as income under the Act of September 8th, 1916. If this latter decision by the lower court is eventually upheld by the Supreme Court, it may invalidate the provision of the present Act with respect to the taxable status of stock dividends. Until the highest court has passed upon the matter, however, the re- cipient of stock dividends has no option and must make his return in ac- cordance with the provisions of the Act. In the event of the higher court affirming the opinion of Judge Mayer of the District Court, the taxpayer would have recourse to an application for refund of tax illegally assessed. (In the case of Towne vs. Eisner, the United States Supreme Court held that under the provisions of the Act of Oct. 3, 1913, effective from Mar. 1, 1913, to Dec. 31, 1915, stock dividends were not taxable income. That Act, however, did not specify stock dividends as taxable income, and the tax was levied under a ruling of the Treasury Department. This omission was corrected in the Acts of 1916, 1917 and the present Act. 187 INDIVIDUALS— Continued INCOME— Dividends The court held in effect that a dividend paid in stock did not distribute any assets of the company, but constituted merely a change in the form of the evidence of ownership of such assets. The theory behind the specific taxation of stock dividends in the Acts of 1916, 1917 and 1918 is obviously that a corporation could indefinitely accumulate and conserve its profits, and thus escape taxation on such profits during a period in which the Gov- ernment needs every dollar of revenue.) 1122- A stock dividend is a distribution by a corporation to the stockholders of capital stock of the distributing corporation. A distribution of capital stock other than that of the distri- buting corporation is not a stock dividend but a dividend in property. 112a- A stock dividend shall be considered income to the amount of the earnings or profits so distributed. Here is an important distinction. In effect the law says that the value of stock received as a dividend out of earn- ings shall be for taxation purposes, not its market value, but the valuation placed upon it by the distributing corpora- tion, which should represent the amount of earnings, profits or surplus distributed. —ILLUSTRATION. Corporation A, with a capital stock of $10,000,000 par value $100 per share and an accumulated surplus of $5,000,000 decides to capitalize this accumulation and dis- tribute the same to stockholders in the form of a dividend. After such distribution is made the market price of the $15,000,000 capital stock, may be, say, $75 per share, and the market value of the $5,000,000 stock distributed would be $3,750,000. The corporation, however, has reduced its profit and loss surplus by $5,000,000 and in its balance sheet has substituted an item of $5,000,000 additional capital stock for the $5,000,- 000 profit and loss surplus. For taxation purposes, there- fore, the value of the stock distributed is $5,000,000, and the taxable value per share would be $100. If the stock of a corporation had no par value, the distri- bution might have been, say, 50,000 shares of stock, but the value of the earnings or profits so distributed would be $100 188 INDIVIDUALS— Continued INCOME— Dividends per share, provided the assets distributed were valued at $5,000,000 by the corporation. 1I24-. Stock dividends are taxable to the recipient at the rates of tax in effect during the calendar year in which received, except that any stock dividend (1) received by a taxpayer between January 1st and November 1st, 1918, both dates inclusive, or (2) during such period is bona fide authorized or declared, and entered on the bookg of the corporation, and received by a taxpayer after November 1, 1918, and before the expiration of 30 days after the passage of the Revenue Act of 1918, then such stock dividend shall, in the manner provided in Section 206 (parts of income subject to rates for different calendar years) , be taxed to the recipient at the rates prescribed by law for the years in which the corporation accumulated the earnings or profits from which such dividend was paid, but the dividend shall be deemed to have been paid from the most recently accumulated earnings or profits. As an illustration of the above paragraph, assume that a taxpayer received income for the calendar year 1918 as follows : Net income from ordinary sources $18,000 Dividends declared and paid in stock on March 1, 1918, designated by the corporation as having been paid from surplus accumu- lated during the year 1917 12,000 Total net income $30,000 Deduct dividends before computing normal tax 12,000 Net income less dividends $18,000 Specific exemption (married man) 2,000 Net income subject to normal tax $16,000 Normal tax (6% on first $4,000) 240 12% on balance of $12,000 1,440 Surtax on $18,000 (at 1918 rates) 550 Total normal and surtax (net income less stock dividends) at 1918 rates $2,230 Computation of tax on the above stock dividends (paid from 1917 earnings) : Net income (exclusive of the stock dividends) $18,000 189 INDIVIDUALS— Continued INCOME— Dividends Sto.;k dividends $12,000 Total 1918 net income $30,000 Of the $12,000 of stock dividends the first $2,000 taxable at the 1917 rates between $15,000 and $20,000 @ 5%: $2,000 @ 5% $100 The balance or $10,000 taxable at the 1917 rates between $20,000 and $40,000 @ S%: $10,000 @ 8% $800 Surtax on stock dividends at rates in effect for the year 1917 $900 Add — normal and surtax (on net income less stock dividends) at 1918 rates 2,230 Total $3,130 It will be seen from the above computation that if the stock dividends received in the year 1918 were taxable at the rates in effect for the year 1918 instead of at the rates of the year 1917, the amount of $12,000 would be taxable at from 8 to 1 4 per cent, while the tax at the 1917 rate is only from 5 to 8 per cent. If 25 — Distribution of Assets in Liquidation. Amounts distributed in the liquidation of a corporation shall be treated as payments in exchange for stock, and any gain or profit realized thereby shall be taxed to the distri- butee as other gains or profits. —ILLUSTRATION. In 1912 John Doe purchased 100 shares of the stock of Corporation B for $8,000. The fair value of this stock on March 1, 1913, was, say $9,000. In the year 1918 Corpora- tion B went into voluntary liquidation and by Dec. 31, 1918, had distributed to John Doe cash or its equivalent to the extent of $11,000. For taxation purposes, therefore, his profit is the difference between $9,000 (the fair value of the stock on March 1, 1913) and $11,000, or $2,000. Any additional cash or its equivalent that might be dis- tributed from the assets of the corporation in the year 1919 would be included as profits in John Doe's return for the year 1919. Conversely, if, after complete liquidation of the assets of Corporation B, John Doe received less than $9,000, he could deduct such difference as a loss, but only after the 190 INDIVIDUALS— Continued INCOME— Dividends liquidation of the assets of Corporation B had become a completed and closed transaction. ]j 26 — Dividends Paid With Securities. Dividends declared by a corporation and paid with securi- ties in which the surplus of the corporation has been in- vested, regardless of the character of such securities, is to be accounted for as a dividend for income-tax purposes by the recipients of same to the extent that it represents a dis- tribution of surplus accrued to the corpc|fation since March 1, 1913.— Art. 4, Reg. 33, Revised. See 11 23 above. If 27 — Dividend Payable in Liberty Bonds. An opinion has been rendered that where stockholders of a corporation receiving a dividend declared payable and dis- tributable in Liberty bonds, the same should be returned as income — Opinion Attorney General. — Treasury Decision 2512, June 8, 1917. The Commissioner of Internal Revenue has ruled that when dividends are paid in Liberty bonds, the amount to be returned by the taxpayer as income shall be the market value of the bonds at the time of receipt. This ruling appears to be in conflict with the opinion of the Attorney General, in which it was held that dividends paid in Liberty bonds were taxable to the recipient "to the amount of the earnings or profits invested by the corpora- tion in the bonds." These two contrary opinions will probably be clarified at an early date by the issuance of a Treasury Decision. If 28 — Dividends Paid Out of Amounts Set Aside for Depreciation. Dividends paid out of reserves set aside for depreciation do not represent a distribution of capital assets. All such dividends received by stockholders declared out of such re- serves accumulated subsequent to March 1, 1913, constitute income to the stockholders and must be accounted for in returns of net income. — Treasury Decision 2540, October 10, 1917. 191 INDIVIDUALS— Continued INCOME— Dividends ^ 29 — Dividends to be Included in Return. Dividends must be included in a return of income, but persons subject to the normal tax only are permitted to deduct from their net income the amounts so received. Un- der the law, corporations, joint-stock companies, associa- tions, etc., are taxed directly on the net income avail- able for payment of such dividends ; theref ore,the individual stockholder has indirectly paid the normal tax on income derived from that source before receiving his dividends. If 30 — Dividends Are Subject to Additional Tax. For the purpose of ascertaining the amount upon which the normal tax of 6 and 12 per cent, is chargeable, a person having a net income of over $5,000, and therefore subject to the additional tax, may deduct income received as dividends from net income, to ascertain the normal tax, but the additional tax is levied against net income exceeding $5,000, including dividends. ♦ —EXAMPLE. For instance, a person having an income of $15,000 from dividends and $15,000 from other sources may deduct from his total net income of $30,000 the $15,000 received as divi- dends, leaving a net income of $15,000, subject to the normal tax. He would, however, be obliged to pay an additional tax on the amount by which his total net income, including divi- dends, exceeded $5,000. His income, subject to the addi- tional tax, therefore, would be $25,000. ^ 31 — Rentals Paid Direct to Bondholders and Stockholders. While the payments made by the lessee direct to the bond- holders or stockholders are rentals to both it and the lessor, rentals paid in one case and rentals received in the other, to the bondholders and the stockholders they are interest and dividend payments received as from the lessor, and as such will be accounted for in their returns of annual net income. —Art. 103, Reg. 33 Revised. ^ 32— Stock Trust Certificates. Stock trust certificates or leased line certificates, as the case may be, issued by the lessee for the purpose of securing 192 INDIVIDUALS— Continued INCOME— Dividends or holding control of the stock, of the lessor are held to be issued in lieu of the certificates of capital stock, and for the purpose of this tax will be treated as capital stock and the amounts received by the holders of these certificates are dividends to the holders, to be treated as rentals by both lessee and lessor and constitute an allowable deduction in the one case and an item of income in the other, accordingly as they are paid and received. — Art. 104, Reg. 33, Revised. T[ 33 — Dividends from Stock or Net Earnings of Foreign Corporations. Dividends received by citizens or residents from stock or net earnings of foreign corporations not subject to payment of the tax on net earnings imposed by this law, must be included as income by persons subject either to the normal tax only, or to the normal and additional /tax. Such divi- dends cannot be deducted from gross income. Tf 34 — Dividends Paid by Foreign Corporations from Earnings Wholly in United States. Dividends declared and paid by a foreign corporation which derives its entire income from business done wholly within the United States and pays, under the 'provisions of the Federal Income Tax Law, a tax upon its net income, should be treated in the same manner as dividends from domestic corporations. — ^Treasury Decision 2090. ^ 35 — Record Owner of Stocks When Another Is Actual Owner. Where a person holds, in his own name, stocks which actually belong to another, such person is not required to include dividends from such stocks in his own return, unless a question be raised as to why such dividends were not in- cluded. In such circumstances the record owner may be re- quired to show that actual ownership rests with another. —ILLUSTRATION. On Jan. 1, 1918, John Doe purchases 100 shares of X. Y. Z. stock at $100 per share through Smith, Jones & Co., his brokers, and makes a partial payment of $1,000 on the total 193 INDIVIDUALS— Continued INCOME— Dividends purchase price of $10,000, borrowing the remainder from his brokers and depositing with them the 100 shares of stock as security for the loan. The stock is transferred to the name of Smith, Jones & Co., the brokers, who thus be- come the record owner, while John Doe is the actual owner. On July 2, 1918, John Doe sells the 100 shares at 95, rep- resenting a loss of $500, but meantime the record owners. Smith, Jones & Co. have received two dividends on the stock amounting to $400, which amount was duly credited to the account of John Doe as actual owner. The correct accounting of John Doe for tax purposes would be as follows. Cost price $10,000 *Commissions 25 Total cost $10,025 Sale price » 9,500 Deductible loss $525 *See H 125. It will be noted that he received dividends of $400 from X. Y. Z. stock and that amount would be included in his statement of gross income from all sources, but for purposes of the normal tax only, he is allowed to deduct that amount as a credit. If he be subject to the additional tax the amount must be included as income subject to such addi- tional tax. John Doe also paid to his brokers $270 as interest on the loan of $9,000 for six months. This would be a separate deduction from his net income under the head of interest paid on indebtedness. TI 36 — Scrip Dividends. A dividend paid in scrip is held to be equivalent to a pay- ment in cash, and should be returned as income to the amount of its face value. Compare If 312. A scrip dividend is a written promise of a corporation to pay a fixed sum of money at a future date, in lieu of cash, and is virtually the equivalent of a promissory note. 194 INDIVIDUALS— Continued INCOME—Dividends Tf 37 — State Taxes on Capital gtock of Banks. State taxes on capital stock of banks, paid by banks are assessed against the individual stockholder and constitute an allowable deduction in the return of such individual. If such individual is subject to the additional tax, the amount of taxes so paid should be included in his return as income, the said amount being included as additional divi- dends to the amount of taxes paid. Claim for deduction of the amount should then be made under the heading "Taxes.*' ]f 38 — Compensation of Stockholders of a Close Corporation. When a company composed of two stockholders divide profits between them, calling it compensation, same cannot be deducted as expense of business. Money paid out under those circumstances is equivalent to dividends and must be treated as income of the corporation. With respect to amounts ostensibly paid as compensa- tion for services of officers and employes of business enter- prises, the Government is interested and authorized to see that expenditures of this character are "necessary" as the law provides that in the case of individuals and corpora- tions only "the necessary expenses paid in carrying on business" shall be allowed as a deduction. The question of deductibiHty will be considered with pay- ments made for services and amounts ordinarily paid for like services in other enterprises of a similar character, or whether the same include some other element. The following will be taken into consideration in this con- nection. Any amount paid in form of compensLti' but not in fact as the purchase price of services, is not deductible. An ostensible salary may be a distribution of dividends, which is likely to occur in corporations having a few stock- holders, and a part of the salary in cases of this kind would not be considered as being paid for services wholly ren- dered. This condition may also arise where salaried em- ployes own a majority of the stock, as the payment of an ostensible salary may be in part a waste or appropriation of assets of the corporation. 195 INDIVIDUALS— Continued INCOME— Miscellaneous An ostensible salary may be paid in part payment for property. This is occasioned by a partnership selling out to a corporation, the partners continuing in the service of the corporation, and it may be found that the salary in part constitutes payment for the transfer of their business. In the case of contingent compensation, consideration will be taken of the fact as to whether the agreement was made before or after the services were rendered, and the facts surrounding the transaction. For full details see Index "Treasury Decisions" ; Treasury Decision No. 2696. ^ 39 — Dividends Paid on Life Insurance Policies. Dividends paid on life insurance policies that have not matured are not taxable income. Dividends from paid-up policies must be included as income — Treasury Decision 2137. ^ 40 — Limited Partnerships. Income from limited partnerships of the Pennsylvania type, where the liability of all the members is limited and the respective partnership shares are transferable much the same as corporate shares, is to be treated as income re- ceived from corporate dividends. Limited partnerships of the New York type which cannot limit the liabilities of the partners and where the respective partnership shares are not transferable, the partners not having the privilege of sueing in the partnership name are not to be classed as corporations and the income received from this class of partnerships is to be treated as ordinary Pi itne^ship profits. — See Treasury Decision 2711. H 41 — Personal Service Corporations. (For definition of a "Personal Service Corporation," see Law, page 52, line 45. Personal service corporations shall not be subject to taxa- tion as corporations, but will be required to make returns as partnerships and the individual stockholders shall be taxed in the same manner as the members of partnerships, and all the profits of the taxable year shall be taxed to the 196 INDIVIDUALS— Continued INCOME— Miscellaneous distributees and any portion remaining undistributed at the end of the taxable year shall be assigned to the respective shareholders in proportion to their stockholdings. If 42 — Permanent Improvements Under Lease or Rental Contracts. When improvements become a part of real estate, the difference between cost of the improvement and a rea- sonable allowance for exhaustion, wear and tear, and obso- lescence during the lease term, is gain or profit to the lessor at the end of the lease term and is to be accounted for as income at that time. — Treasury Decision 2442 ; also Art. 4, Reg. 33, Revised. —ILLUSTRATION. A leases a plot of ground from B for a term of five years under a stipulation that any permanent improvements made thereon by A during the term of the lease, become the prop- erty of lessor B at the termination of the lease. Lessee A erects a public garage on the leased plot at a cost of $3,000. At the end of five years title to this garage passes to lessor B. For income tax purposes the income of lessor B has been increased by $3,000, the cost of the garage, less a reasonable allowance for exhaustion, wear and tear, and obsolescence. Tf 43 — Income from Sale of Property. For the purpose of ascertaining the gain derived from the sale or other disposition of property, real, personal, or mixed, acquired before March 1, 1913, the fair market price or value of such property as of March 1, 1913, shall be the basis for determining the amount of such gain derived. (Law, page 54, line 13.) ^ 44 — Income from Sale of Personal Property on the Installment Plan. It has been ascertained that dealers in personal property who sell on the installment plan adopt one of four ways of protecting themselves in case of default, namely : (1) A provision that title is to remain in the seller until the buyer has performed his part of the agreement. 197 INDIVIDUALS— Continued INCOME— Miscellaneous (2) A conveyance of title to the purchaser subject to a lien for the unpaid portion of the purchase price. (3) The conveyance to the purchaser and an immediate reconveyance by way of chattel mortgage to the seller. (4) Conveyance to a trustee in trust to hold the title pending performance of the contract and subject to its pro- visions. The purpose is the same in all of these transactions. In view of the fact that in a number of States it is held that the form first mentioned shall not be enforced accord- ing to its terms, but will be regarded as a sale with a chattel mortgage back to secure the unpaid purchase price, it is desirable that a uniform rule be established which will be equitable and applicable to all. The rule prescribed is that in the sale or contract for sale of personal property on the installment plan, whether or not title remains in the vendor until the property is fully paid for, the income to be returned by the vendor will be that proportion of each installment payment which the gross profit to be realized when the property is paid for bears to the gross contract price. If, for any reason, the vendee de- faults in his installment payments and the vendor repos- sesses the property, the entire amount received on install- ment payments less the profit originally returned will be income to the vendor to be so returned for the year in which the property was repossessed. (This ruling amends Articles 117 and 120 of Regulations 33, Revised, relating to the Revenue Act of 1916, and re- vokes all previous decisions and rulings which are in conflict herewith. — Treasury Decision 2707.) K 45 — Method of Determining Value as of March 1 , 1 91 3. No method of determining this value can be stated by the department which will adequately meet all circumstances. What that value was is a question of fact to be established by any evidence which will reasonably and adequately make it appear. — Art. 4, Reg. 33 Revised. In the case of real property, if the fact can be estabhshed that a bona fide offer was received approximately at this 198 INDIVIDUALS— Continued INCOME— -Miscellaneous date or a competent appraisal was made based on surround- ing values, this would be an equitable basis upon which to establish the fair market value as of this date. In the case of securities, the average market value between the opening and the closing price of March 1, 1913 is the basis. For income tax purposes, where there is an actual sale and transfer, profit will be considered as realized even though payment is to be made in installments, as notes for deferred payments are secured by the title to the property and presumably bear interest and are held to be worth, in cash, their face value. In case of default on installment payments there may be charged off as bad debts the amount of such unpaid install- ments less the salvage value of the real estate repossessed. — Treasury Decision 2090. Tf 46 — Income Received by Estates of Deceased Persons. Income received by estates of deceased persons during the period of administration or settlement of the estate is sub- ject to the normal and additional tax, and will be taxed to their estates. — Law, page 67, line 36. Tf 47 — Income of Estates or Property Held in Trust. Such income of estates or any kind of property held in trust, including such income accumulated in trust for the benefit of unborn or unascertained persons, or persons with contingent interests, and income held for future distribution under the terms of the will or trust, shall likewise be taxed. Except where such income is returned for the purpose of tax by the beneficiary,the tax in each instance will be assessed to the executor, administrator or trustee. Where the income is to be distributed annually or regu- larly between existing heirs or legatees or beneficiaries, the rate of tax and method of computing the same shall be based in each case upon the amount of the individual share distributed, and the tax shall be paid by the bene- ficiaries and not by the fiduciary. 199 INDIVIDUALS— Continued INCOME— Miscellaneous Tf 48 — Bonds Purchased Between Interest Dates. Interest accrued to the time of purchase (advanced by purchaser) is not to be accounted for as income by the purchaser. Only the amount of interest assignable to the portion of the interest period subsequent to the pur- chase has a status of income for the purposes of return and tax by purchaser. The amount of accrued interest so advanced by the pur- chaser is taxable income to be accounted for in the return of the vendor. — Art. 4, Reg. 33, Revised. Where a taxpayer purchases a 6% $100 coupon bond at it face value, plus $1.50 — that is three months' accrued interest — and three months later detaches a coupon there- from and collects $3 interest, it is necessary to report in your return only so much interest as accrued after the date of your purchase. It is the seller's duty to report the bal- ance. — Primer, Question 42. If 49 — Bonds^ — Coupons Exchanged for Other Bonds. Coupons from bonds for interest thereon, exchanged for other bonds, are held to be the equivalent of payment of the interest coupons and purchase of the new bonds with the cash. The amount of the coupons is to be accounted for as income for the calendar year in which the exchange is made. — Art. 4, Reg. 33, Revised. If 50 — Building and Loan Associations. Amount credited to shareholders of building and loan associations, when title to such credit passes to the share- holder at the time of the credit, has a taxable status for the normal and additional tax as for the year of the credit. Where the amount of such accumulations does not "become available to the shareholder until the maturity of a share, the amount of a share in excess of the aggregate amount paid in by the shareholder is income to be accounted for as for the year of the maturity of the share for both the normal and additional tax. — Art. 4, Reg. 33, Revised. Tf 51 — Bonus in Common Stock. Where common stock is received as a bonus in considera- tion of the purchase of preferred stock, the entire proceeds 200 INDIVIDUALS— Continued INCOME— Miscellaneous derived from the sale or transfer of such stock is income subject to the normal and additional tax. — Art. 4, Reg. 33, Revised. U 52 — Commissions on Renewal Premiums for Insurance. An amended return is required in cases where receipts from this source were not included in 1913 return. — Treas- ury Decision 2011. Any commissions received by insurance agents on account of business written are taxable income for the year in which received. — Primer, Question 40. Tf53 — Commission Retained by Agent on His Own Life Insurance. Commission retained by agent on his own life insurance policy is held to be income accruing to the agent, and should be included in his return of income for the assessment of the income tax. ^ 54 — Compensation for Service Upon an Annual, Monthly or Weekly Basis. Where a service and payment period is divided by the end of a taxable year, the compensation for the period so divided at the end of the year will be accounted for in the return for the year in which payment is made and received. Where the service is of such nature as to be compensated by fee, or of such nature that no portion of the amount becomes due until the service is completed, then the total amount of the compensation should be included in the return for the year in which the compensation is received. — Treas- ury Decision 2090. Tf 55 — Compensation Not Paid in Money. Where service is rendered for stipulated price, wage, or salary and paid with something other than money, the stipu- lated value of service in terms of money is the value at which the thing taken in payment is to be considered for the purpose of the income tax. Where there is no stipulation as to the value of service and payment for service is made with something other than money, the market or reasonable value of the thing 201 INDIVIDUALS— Continued INCOME— Miscellaneous taken in payment is the amount to be included as income for the purposes of the income tax. — Art. 4, Reg. 33, Re- vised. Where a person receives a cash compensation for services rendered, and in addition thereto commissions, living ex- penses and other allowances, a return is required in each case where the cash compensation plus the value of the allowances equals or exceeds $1,000 for the tax year. — (Primer, Question 135.) Board and lodging, or other consideration received in lieu of rental or cash, is considered income equal in amount to the indebtedness in payment of which it is received, and should be included in any return of annual net income its recipient is required to render. — Treasury Decision 2137. 1156 — Farm Products — Income From — How Treated. Income from farm products and crop-share rentals to be included in return of income for year in which sold or exchanged for money, or a money equivalent. — Treasury Decision 2153. T[ 57— Farm. The term "farm" as herein used embraces the farm in the ordinary accepted sense, plantations, ranches, stock farms, dairy farms, poultry farms, fruit farms, truck farms and all lands used for similar purposes; and for the purposes of this decision all persons who cultivate, operate, or manage farms for gain or profit, either as owners or tenants, are designated as "farmers." 1158- All gains, profits, and income derived from the sale or exchange of farm products, whether produced on the farm or purchased and resold by a farmer, shall be included in the return of income for the year in which the products were actually marketed and sold; and all allowable deduc- tions, including the legitimate expenses incident to the production of that year or future years, may be claimed in the return of income for the tax year in which the right to 202 INDIVIDUALS— Continued INCOME— Miscellaneous such deduction shall arise, although the products to which such expenses and deductions are incidental may not have been sold or exchanged for money, or a money equivalent during the year for which the return is rendered. Rents received in crop shares shall likewise be returned as of the year in which the crop shares are reduced to money or a money equivalent, and allowable deductions likewise shall be claimed in the return of income for the tax year to which they apply, although expenses and deductions may be incident to products which remained unsold at the end of the year for which the deductions are claimed. When farm products are held for favorable market prices, no deduction on account of shrinkage in weight or physical value or losses by reason of such shrinkage or deterioration in storage shall be allowed. — Art. 4, Reg. 33, Revised. Tieo- The value of grain, stock, and other products produced on a farm is not considered taxable income until reduced to cash or the equivalent of cash. Therefore, if crops and stock were produced in 1917 on a farm owned and they were sold in 1918, the total amount received therefor is to be included under "Gross Income" in the 1918 return. Crops and stock produced in 1918, and on hand December 31 of that year, need not be considered; but the amount re- ceived therefor should be included in the return rendered for the year during which they are sold. Farmers who keep books according to some approved method of accounting, which clearly show the net income, may prepare their returns from such books, although the method of accounting may not be strictly in accordance with the above paragraph. — Primer, Question 28. A farmer is not required to report the value of the farm, produce which is consumed by himself and family ; but any amount of expense incurred in producing garden truck, or 203 INDIVIDUALS— Continued INCOME— Miscellaneous other products so consumed, cannot be claimed as a deduc- tion. — Primer, Question 30. The price placed by the merchant upon the goods ex- changed for farm produce is to be included as income in the farmer's return. — Primer, Question 31. ^ 64 — Life Insurance. Where insured receives, under any form of life insurance, an amount in excess of premiums paid for the insurance, such excess has a taxable status and is to be accounted for as for the calendar year of its receipt. — ^Art. 4, Reg. 33, Revised. Tf 65 — Dividends on Paid-up Policies. Dividends on paid-up policies are in the nature of cor- porate dividends and are to be accounted for as income for the purposes of the additional tax only. — ^Art. 4, Reg. 33, Revised. ^ 66 — Endowments. Where a taxpayer receives $1,000 in 1918 on the maturity of an endowment life insurance policy upon which pay- ments have been made for 20 years, only the difference be- tween the aggregate amount of premium paid and the amount received upon the maturity of contract is to be in- cluded in income tax return. fl 67 — Other Taxable Income from Insurance. For other taxable income from life insurance see Index, "Life Insurance." ^ 68 — Living Quarters Furnished as Part of Compensation. Where an individual is furnished living quarters in addi- tion to salary the rental value of such living quarters is regarded as compensation subject to the income tax. — Treasury Decision 2090; also, see H 55. ^ 69— Mileage. The difference between the amount received as mileage and the amount of actual necessary expenses incurred on 204 INDIVIDUALS— Continued INCOME— MisceUaneous a journey shall be returned as income. — Treasury Decisions 2090 and 2079; also, see If 73. - If 70 — Officer or Employe of a State. An individual who enters into a contract with a State, or any political subdivision thereof, for the doing of a thing or things specified by the contract, the completion of which will constitute a fulfillment of the contract on the part of such individual, is not an officer or employee of the State or political subdivision thereof within the meaning and intent of Section 4 of the Income Tax Law and the amount received by him from the State or political subdi- vision thereof under the terms of the contract is to be accounted for as income. — ^Art. 4, Reg. 33, Revised. ^ 71 — Pensions. Pensions paid by the United States, private institutions, or individuals are to be accounted for, for income tax pur- poses, in all cases where income of the pensioner is liable for income tax. — Art. 4, Reg. 33, Revised. II 72— Profit from the Sale of Stock. When stock is sold from lots purchased at different times and at different prices and the identity of the lots can not be determined as to dates of purchase, the stock sold shall be charged against the earliest purchases of such stock. The difference between cost and amount realized on the sale will be the profit to be accounted for as income if the purchase was on or after March 1, 1913. Profit derived from the sale of stock purchased prior to March 1, 1913, is the difference between the fair market price or value as of that date and the selling price. — Art. 4, Reg. 33, Revised. Tf 73 — Per Diem Allowances in Lieu of Subsistence While Traveling Under Orders. The difference between the amount received as a per diem allowances and the amount of actual necessary expenses in- curred on a journey shall be returned as income. An amount equal to ordinary home living expense should be excluded as the same is not a proper deduction. 205 INDIVIDUALS— Continued INCOME— Miscellaneous It 74— Proceeds of Sale of "Rights" Income. In cases wherein corporations desiring to secure addi- tional capital propose to issue and sell further shares of stock, reserving to their stockholders the right to subscribe for, at par or any other stipulated price, a certain number of shares of the new stock issue, proportioned to the number previously held, and if such stockholders shall sell their rights, it will be held that the proceeds of such sale are in their entirety income for the year in which the rights are sold, and should be so returned by the stockholders, whether they be individuals or corporations. — Art. 95, Reg. 33, Re- vised. If 75— Sale of Stock Acquired by Gift. The fair market price or value of stock acquired by gift subsequent to March 1, 1913, is the basis for computing gain derived or loss sustained by the sale thereof. If ac- quired by gift prior to March 1, 1913, the fair market price or value as of that date is the basis for computation. — Art. 4, Reg. 33, Revised. 1j 76— Rent. Amounts expended by tenants for taxes and necessary repairs under agreement, in addition to a stipulated cash rental, are items of taxable income, and as such should be reported in the return of the landlord. A corresponding amount may be deducted by the landlord. Tl 76(a)— Retired Pay. Retired pay of Army and Naval officers and judges of the United States courts is subject to the income tax. ]j 77— Royalty. Royalty paid to a proprietor by those who are allowed to develop or use property, or operate under some right be- longing to him, is to be accounted for as income. — Art. 4, Reg. 33, Revised. ^ 78— Warrants of City, Etc. In cases wherein warrants are issued by a city, town, or other political subdivision of a State, and are accepted by 206 INDIVIDUALS— Continued INCOME— Miscellaneous the contractor in payment for public work done, the face value of such warrants must be returned as income for the year in which they are received. If, for any reason, the contractor upon conversion of the warrants into cash, does not receive and can not recover the full face value of the warrants so returned, he may allowably deduct from gross income for the year in which the warrants' are converted into cash, any loss sustained, which loss will be measured by the difference between the face value of the warrants returned as income and the amount actually re- ceived for them in cash, or its equivalent, when redeemed or disposed of. — Art. 108, Reg. 33, Revised. Tl 7d — Compensation. If an employe's total compensation, salary and bonus is fixed, determined, and paid to him at one time, the same should be considered income for the year in which received. It follows that where a part of the compensation is in the form of a salary payable monthly, and a part in the form of a bonus not fixed and determined until on or after Jan- uary 1 of the year following that in which the services were rendered, the two parts of any one year's compensation can not be considered together for the purpose of including both amounts in the same year; but the fixed salary of one year should be considered together with the bonus received on or after January 1 of that year. Thus, if the services were rendered in the year 1914 the employe's com- pensation would be liable to tax together with the fixed salary and the bonus paid on or after January 1, 1914. The bonus to be paid on or after January 1, 1915, will belong to the tax year 1915, together with the fixed salary re- ceived during 1915. — Treasury Decisions 2135 and 2616. Tl 80— Bonuses. The question of when a bonus is taxable to the employe receiving it and when it is exempt from taxation in his hands has always been a perplexing one to a great many taxpayers. In most cases a bonus is in reality only additional salary or compensation and not an actual gift. The determining INDIVIDUALS— Continued INCOME— Miscellaneous factor is whether or not it has been charged off by the payor (corporation, firm or individual) as an expense. If the payor has not charged off as expense the amount paid as bonuses, then it is, in fact, a gift to the employe and is free of tax in his hands; but if the payor charges off the bonuses on his books as an expense, the same as salary, it naturally follows that the payor has paid no tax on this amount so charged off and it is therefore not a gift but has the status of additional salary or compensation and is tax- able in the hands of the employe as such. Tf 81 — Salary and Commissions. A person receiving a salary and in addition a commission of 1 per cent, on all sales, the exact amount due on account of commissions not being determinable until February fol- lowing the year in which the commissions were earned, at which time both his salary for the preceding year and his commissions are paid to him, should return as income, for the year in which payment was made, the aggregate amount received on account of salary and commissions. ^ 82 — Salaries Paid by Organizations Exempt From the Income Tax. Salaries paid by exempt corporations are subject to the income tax and should be returned as income by the indi- vidual. — Treasury Decision 2090. Tf 83 — Special Compensation for Service Rendered. ^ Special compensation for service rendered must be in- cluded as income. If 84 — Voluntary Offerings. Easter offerings, and fees received by clergymen for funerals, masses, marriages, baptisms, etc., are considered income subject to tax under the provision of the Income Tax Law of October 3, 1913. Christmas gifts, however, are not considered income within the meaning of the law and should not be included in a return. — Treasury Decision 2090. 208 INDIVIDUALS— Continued INCOME— Tax Exempt ^ 85^ — Where an Employe Is Paid Two Years' Salary Conditionally. Where an employe is paid a sum equal to two years' salary on condition that he surrender his contract of em- ployment, such sum should be reported by him on his annual return as income. ]\ 86 — Income Exempt from Tax. (See Law, page 60, line 35.) The following income is exempt from the provisions of the law and is not to be included in a return of income : (1) The proceeds of life insurance policies paid upon the death of the insured to individual beneficiaries or to the estate of the insured ; (2) The amount received by the insured, as a return of premium or premiums paid by him under life insurance, endowment, or annuity contracts, either during the term or at the maturity of the term mentioned in the contract or upon the surrender of the contract. (3) The value of property acquired by gift, bequest, devise, or descent (but the income from such property shall be included as income) . (4) Interest upon (a) the obhgations of a State, Terri- tory, or any political subdivision thereof, or the District of Columbia, or (b) securities issued under the provisions of the Federal Farm Loan Act of July 17, 1916; or (c) the obligations of the United States or its possessions, or (d) bonds issued by the War Finance Corporation. In the case of obligations of the United States issued after September 1, 1917, and in the case of bonds issued by the War Finance Corporation, the interest shall be exempt only if and to the extent provided in the respective Acts authorizing the issue thereof, and shall be excluded from gross income only if and to the extent it is wholly exempt from taxation to the taxpayer both under this title and under Title III. Every person owning any of the obligations, securities or bonds enumerated in paragraph (4) shall submit with his return of income a statement in such form and with such INDIVIDUALS— Continued INCOME— Tax Exempt information as the Commissioner of Internal Revenue may require, showing the number and amount of such obhga- tions, securities and bonds so owned and the income re- ceived therefrom. (5) The income of foreign governments received from investments in the United States in stocks, bonds, or other domestic securities, owned by such foreign governments, or from interest on deposits in banks in the United States of moneys belonging to such foreign governments, or from any other source within the United States. (6) Amounts received, through accident or health insur- ance or under workmen's compensation acts, as compensa- tion for personal injuries or sickness, plus the amount of any damages received whether by suit or agreement on account of such injuries or sickness ; (7) Income derived from any public utility or the exer- cise of any essential governmental function and accruing to any State, Territory, or the District of Columbia, or any political subdivision of a State or Territory, or income accruing to the government of any possession of the United States, or any political subdivision thereof. Whenever any State, Territory, or the District of Colum- bia, or any pohtical subdivision of a State or Territory, prior to September 8, 1916, entered in good faith into a contract with any person or corporation, the object and purpose of which is to acquirt;, construct, operate, or maintain a public utiHty, no tax shall be levied under the provisions of this title upon the income derived from the operation of such public utility, so far as the payment thereof will impose a loss or burden upon such State, Territory, District of Colum- bia, or political subdivision; but this provision is not in- tended to confer upon such person or corporation any finan- cial gain or exemption or to relieve such person or corpora- tion from the payment of a tax as provided for in this title upon the part or portion of such income to which such person or corporation is entitled under such contract; (8) So much of the amount received by a person in the military or naval forces of the United States as salary or 210 INDIVIDUALS— Continued INCOME— Tax Exempt compensation in any form from the United States for active services in such forces as does not exceed $3,500. The word "United States" as used in this title shall be construed to include the States, the Territories of Alaska and Hawaii, and the District of Columbia. — Law, page 51, line 20. ^ 87 — Political Subdivision of State. A political subdivision as here used is held to mean a district, division, or community created by proper State authority and which, by virtue of such authority is vested with power to exercise certain governmental functions, such as prescribing regulations for its government, the exercise of certain police powers, the assessment and collection of taxes, etc. — Art. 83, Reg. 33, Revised. ^ 88 — Obligations of State, Etc. Obligations issued by the duly constituted authorities of such, a community so organized and empowered are the obli- gations of a political subdivision of the State, and the interest received on obligations of this character is ex- empt from the taxes imposed by the Revenue Act of 1918 subject to the provisions of Section 213 (Law, page 60, lines 10 and 48). However, a district without power to ex- ercise any governmental function, created for the purpose of making some improvement, primarily beneficial, to the property located in and comprising the district, is not, within the meaning of these acts, a political subdivision of the State. Obhgations issued in payment for such im- provement, although guaranteed by a county, municipality, or other poHtical subdivision of the State, are not the obligations of the State or of any political subdivision thereof; but are rather the obligations of the benefited property upon which they constitute a lien. Hence, the income derived from obligations, which are a direct charge against or lien upon benefited property, is not exempt from these taxes, and must be returned as income of the recipient. —Treasury Decision 1946.— Art. 84, Reg. 33, Revised. 211 INDIVIDUALS— Continued INCOME— Tax Exempt If 89 — Obligations of the United States. Section 213 of the Revenue Act of 1918 exempts from the tax interest on the obligations of the United States issued after September 1, 1917, only if and to the extent provided in the Acts authorizing their issue ^ 90 — United States Bonds and Certificates Issued Under the Act of September 24, 1917. Said Act provides that bonds and certificates issued there- under shall be exempt from all taxes except estate or in- heritance taxes, additional income taxes, commonly known as surtaxes, and excess or war profits taxes — Art. 85, Reg. 33, Revised. The exemption of interest received after January 1, 1918, upon Liberty bonds is as follows : Interest upon the first issue of 31/2S is totally exempt. If bonds of the first non-taxable issue have been converted into the second, third or fourth issues, they then have the status of "obligations of the United States issued after Sept. 1, 1917" and the interest received upon the converted bonds and the bonds of the second, third and fourth issues is ex- empt from taxation to the following extent: If the tax- payer holds no bonds of the fourth issue, the interest on an aggregate amount of the second and third issues, not ex- ceeding $5,000 of principal, is exempt. As an example, assume the taxpayer has $10,000 of the second issue upon which he receives $400 interest and $10,- 000 of the third issue upon which he receives $425 ; the in- terest upon a total of $5,000 of the entire holding of the first and second issues or $206.25 of the total of $825 interest re- ceived would be exempt. If the taxpayer holds any of the fourth issue, then the interest on an amount of bonds of this issue, the principal of which does not exceed $30,000, is exempt from tax. The interest on bonds of the second and third issues, either con- verted or unconverted, is exempt up to one and one-half times the amount of the bonds of the fourth issue originally subscribed for and held by the taxpayer at the time of making his income tax return, not to exceed an aggregate principal amount of $45,000. 212 INDIVIDUALS— Continued INCOME— Tax Exempt Upon bonds of the first issue of 3i/^s which have been converted into the fourth issue for the purpose of securing any of the exemption privileges arising out of the owner- ship of bonds of the fourth issue, the interest is exempt from taxation to an amount of principal not exceeding $30,000. The above exemptions are in addition to the exemption of an aggregate amount of $5,000 of principal of the second, third and fourth issues, which is provided for in the Acts authorizing the respective issues. These privileges will remain in effect until two years after the date of the termination of the present war with Germany as fixed by proclamation of the President and are accorded to all taxpayers whether individuals, partnerships, associations or corporations. As set forth in the above explanation, it is possible for a taxpayer to secure exemptions on Liberty bonds to a total of $110,000 principal amount, as follows : Fourth issue $30,000 Second and Third 45,000 First converted into Fourth 30,000 Original exemption on Second, Third, Fourth 5,000 Total $110,000 If the owner of the bonds holds less than $30,000 worth of the fourth issue, the amount of the second and third issues exempt is one and one-half times the amount of the fourth issue held, plus the further privileges as outlined above. ^ 91 — Dividends, Federal Reserve Bank. The Federal Reserve Statute, Section 3, of the Act of October 22, 1914, provides that Federal reserve banks and the capital stock and surplus therein, are exempt from taxation. Under this provision of law the exemption provided for in the Federal Reserve Act attaches to and follows the in- come derived from dividends on stock of Federal reserve banks into the hands of stockholders, that is to say, the divi- 213 INDIVIDUALS— Continued • INCOME— Tax Exempt dends received on the stock of Federal reserve banks are ex- empt from the taxes imposed by the Acts of September 8, 1916, as amended, and of October 3, 1917. This ruhng does not contemplate, however, that dividends paid by member banks are exempt from the 2 per cent, tax imposed by this title, but such dividends, in so far as they may be received by other corporations, may be treated as a credit against net income in computing the war income tax imposed by Title I of the Act of October 3, 1917.— Art. 86, Reg. 33, Revised. ^ 92 — Federal Farm Loan Act. Interest on securities issued under provisions of Federal Farm Loan Act, July 17, 1916, is exempt from tax. — Art. 5, Reg. 33, Revised. ^ 93— Christmas Gifts. Christmas gifts are not income within the meaning of the law. — Treasury Decision 2090. ^ 94 — Expense — Reimbursement of. Amounts received from a railway company by way of reimbursement for expenses incident to an accident are not subject to the income tax. — Treasury Decision 2153. H 95— Government Officers and Employes. Treasury Decision 2079 holds that the amount received for, or the money equivalent of. Quarters ; Heat and Light ; Mileage; and Per diem allowance in lieu of subsistence, is taxable income to the recipient, except that the actual cost of a journey should be deducted from "Mileage" and the actual amount expended for subsistence while traveling should be deducted from "Per diem." Section 213 of the Revenue Act of 1918 modifies the above and provides that so much of the salary or compensation re- ceived during the present war for active service in the military or naval forces of the United States as does not exceed $3,500 shall be exempt from income tax. 214 INDIVIDUALS— Continued INCOME— Tax Exempt If 96 — Income from Exempt Securities. Where the entire income of an individual is from tax- exempt bonds and where the amount of income other than that from tax-exempt securities is less-^than the amount of income for which a return is required, no return of income is to be made. Interest from securities which is exempt from tax under the Income Tax Law is not to be included in returns of income. — Art. 26, Reg. 33, Revised. U 97 — Annuity. The amount paid under a life insurance, endowment or annuity contract is not income when returned to the person making the contract, either upon the maturity or surrender of the contract ; but the amount by which the sum received exceeds the sum paid and coming into the hands of the person making the contract and payment, is income. — Treas- ury Decision 2152. ^ 98 — Dividends Paid on Life Insurance Policies. Dividends paid on life insurance policies that have not matured are not taxable income. Dividends from paid-up policies must be included as income. — Treasury Decision 2137. II 99 — Stock Dividends Declared from Special Surplus. Stock dividends declared from a surplus created from the revaluation of capital assets or a value placed upon trade- mark, good will, etc., do not represent a distribution of earn- ings or profits subject to tax in the hands of the recipient shareholder. The entire proceeds derived by a shareholder from the sale of such stock is income subject to both the normal and additional tax and shall be accounted for in the shareholder's return rendered for the year in which sold. — Art. 4, Reg. 33, Revised. HlOO—Salary Paid After Death. Salary of an officer or employe paid for a limited period after his death to his widow in recognition of the services rendered by her husband, no services being rendered by the widow, it is held that such payment is a gratuity and 215 INDIVIDUALS— Continued DEDUCTIONS— Credits exempt from taxation under the Income Tax Law. Such a payment would not, however, be an allowable deduction as an expense of carrying on business in the return of the person, firm, or corporation paying same. — Treasury Deci- sion 2090. If 101 — State or Political Subdivision — Expenses in Con- nection with Salary Received from, Not Allowable Deduction. Expenses incurred in earning income which is not subject to tax under the Income Tax Law do not constitute allowable deductions in computing net income from other sources which are taxable under the law. — Treasury Decision 2137. DEDUCTIONS, EXEMPTIONS AND CREDITS T[102— ALLOWED. In computing taxable income for purposes of the normal tax the following exemptions and deductions are allowed. If 103— Deductions. For the purpose of the normal tax the law allows deduc- tions for expenses, interest on indebtedness, taxes, losses, depreciation, contributions, etc. These items are defined under the head of "Deductions from Income Allowed." — See If S6 (4), 90, 106. ^ 1 04— CREDITS ALLOWED. Income in a personal return for the normal tax shall be credited with amounts received as dividends from a corpora- tion which is taxable upon its net income and amounts re- ceived as dividends from personal service corporations out of earnings or profits upon which income tax has been im- posed by Act of Congress. The amount received as interest upon obligations of the United States and upon bonds issued by the War Finance Corporation, which is included in gross income un- der Section 213.— See If 86 (4), 90, 106,; see also Law, page 60, lines 10-48. 216 INDIVIDUALS— Continued DEDUCTIONS—Expenses If 105— PERSONAL EXEMPTION. The law allows an exemption' in the nature of a deduction from the taxable income the sum of $1,000 plus $1,000 addi- tional if the person making the return be the head of the family or a married person living with husband or wife, and $200 additional for each dependent person. — See |f 216. 11 106— DEDUCTIONS FROM INCOME ALLOWED. (See Law, page 62, line 8.) (For deductions allowed non-resident aliens, see T[ 455.) In computing net income in the case of a citizen or resi- dent of the United States for the purpose of the tax there shall be allowed as deductions. ^107— EXPENSES. All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other compensation for personal services actually rendered, and including rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity. 11108- This includes all amounts actually paid by a farmer for labor in preparing his land for a crop and the cultivation, harvesting, and marketing of the crop ; the cost of the seed and fertilizer used ; the amounts expended for labor used in caring for live stock and the cost of the feed; the cost of stock purchased for the purpose of resale. (It should be understood, however, that if such cost is claimed as a deduc- tion, the entire proceeds received upon a sale of the stock is to be returned as income.) The amounts actually paid in making repairs to farm buildings, but not the dwelling house; repairs to fences, farm machinery, etc.; the cost of materials for immediate use and farm tools which are used in the course of a year or two, such as binding twine, stock 217 INDIVIDUALS— Continued DEDUCTIONS—Expenses powders, pitchforks, spades, etc.; and the amount of rent paid for a farm may also be claimed. The amounts paid for live stock which is to be used for breeding purposes are held to represent investment of capital and are not allow- able as deductions. If 109— A merchant may claim as deductions the amounts paid for advertising, hire of clerks, and other employes ; the cost of the light, fuel, water, telephones, etc., used in or at his place of business; drayage and freight bills; the cost of operating delivery wagons, trucks, and repairs to same. Tfiio— A physician may claim as deductions the cost of medi- cines and medical supplies used by him in the practice of his profession, expenses paid in the operation and repair of an automobile used in making professional calls, dues to med- ical societies and subscriptions to medical journals, the ex- penses of attending medical conventions, the rent paid for office rooms and the hire of office assistants, the cost of the fuel, light, water, telephone, etc., used in such office rooms. Amounts expended for books, medical supplies, and surgical instruments of a permanent character are not allowable as deductions. This in a general way outlines the ordinary and usual ex- penses incurred by a farmer, a merchant, or a professional man, which may be claimed as deductions, and the principles underlying these allowances are equally applicable in the case of anyone engaged in a business, trade, or profession. In short, all expenses connected directly and solely with the conduct of an income-producing business, trade, profession, or vocation are allowable. IfllZ- Items of personal expense or items connected in any way with the support, maintenance, and well-being of a family are not allowed; neither are the amounts paid for tools. 218 INDIVIDUALS— Continued DEDUCTIONS— Expenses implements, vehicles, machinery, or surgical instruments which are more or less permanent in character, nor the cost of medical, law, or other professional books, nor are the amounts expended in making permanent improvements or betterments of any kind whatsoever, allowable as deduc- tions. These latter items are held to be investments of cap- ital upon which depreciation may be claimed. — Primer, Question 59. 11 11 3— Alimony. Alimony is a personal expense and as such is not deduct- able by the payor and is not an item of income to the re- cipient. This was decided by the United States Supreme Court in the case of Gould vs. Gould, dated Nov. 19, 1917. ^11 4 — Orchards and Ranches. Amounts expended in the development of orchards and ranches prior to the time when the productive stage is reached constitute investments of capital. — Art. 4, Reg. 33, Revised. T[ 1 1 5 — Administration of Estates, Expenses of. Referring to the difference between the expenses of ad- ministration of estates, set forth as not allowable deduc- tions in Treasury Decision 2090, and the expenses itemized as allowable deductions on Form 1041, Revised, the distinc- tion is sought to be made between such first expenses as are properly chargeable against an estate as an entity, and such other expenses incident to administration as may arise from the nature of the properties and the details of business man- agement. — Treasury Decision 2135. Tl 110 — Allowances to Minor Children. The father is legally entitled to the service of his minor children. As a rule, allowances which he gives them, whether said to be in consideration of service or otherwise, are not allowable deductions, in his return of income nor are they income to the children. — Art. 8, Reg. 33, Revised. If a taxpayer employs a minor son or daughter to assist him in his business or trade and pays them a salary or wage 219 INDIVIDUALS— Continued DEDUCTIONS— Expenses for such assistance, the amount paid them does not consti- tute an allowable deduction in his return. If, however, the son or daughter has attained his or her majority, the amount of compensation paid for his or her services may be so claimed. — Primer, Question 61. Note: As the ruling was made under the Revenue Act of 1916, as amended by the Revenue Act of 1917, when a minor child was not required to make a return of net income, it would seem to follow that as the Revenue Act of 1918 re- quires a minor child to make a return, the parent will be allowed to deduct these amounts paid, and the minor re- quired to pay a tax thereon if the sum is in excess of $1,000. ]f 1 1 7 — Army Officers — Expenditures From Allowances. The pay and allowance of Army officers are based on the obligation of an officer to provide equipment and mounts as a personal expense. The cost of mounts and equipment is not therefore a deductible expense. — Art. 8, Reg. 33, Re- vised. The Revenue Act of 1918 provides that so much of the amount received during the present war by a person in the military or naval forces of the United States as salary or compensation in any form from the United States for active service in such forces as does not exceed $3,500, shall not be included in income or be taxed to the recipient. U 1 1 8 — Business Insurance. Premiums paid in advance, covering a period of several years, are to be taken as a deduction on the basis of one of two methods : When the books are kept on a cash basis, the entire amount is deductible in the year in which the prem- ium is paid. Where the books are kept on an accrual basis the premium is to be prorated over the period covered by the insurance. — Art. 8, Reg. 33, Revised. |[ 1 1 9 — Commission Paid to Real Estate Agent. A commission paid to a real estate agent for collecting rents and management of property is a legitimate business expense and constitutes an allowable deduction in computing net income. — Treasury Decision 2090. 220 INDIVIDUALS— Continued DEDUCTIONS— Expenses ^1 120 — Commissions Paid Salesmen. Commissions paid salesmen as a part of the expense of conducting business are allov/able deductions to the payer of the commission. Such commissions, however, are income and should be accounted for in the return of the person re- ceiving them. ^121 — Lobbying or Campaign Expenses — Not Deductible. Sums of money expended for lobbying purposes, the pro- motion or defeat of legislation, the exploitation of propa- ganda, and contributions for campaign expenses are held not to be an ordinary and necessary expense in the operation and maintenance of the business of a corporation," and are therefore not deductible from gross income in arriving at the net income upon which the income tax is computed. — • Treasury Decision 2137 ; also Art. 143, Reg. 33, Revised. ^ 1 22^ — Assessments for Reorganization. Amounts to be assessed and paid under a mutual agree- ment between bondholders or stockholders of a corporation, to be used in reorganization of a corporation, are held to be investments of capital and not deductible for any purpose in a return of income. — Art. 8, Reg. 33, Revised. ^ 1 23 — Expenses Incurred in Earning Income Subject to Tax. Amounts paid from a salary received for all services ren- dered, are deductible in returns of income as business ex- penses, when the expenditures are occasioned by the service in respect of which the salary is paid. — Art. 8, Reg. 33, Revised. ^ 1 24 — Expense — Architect's Services a Capital Investment. The amount expended for architect's services is part of the cost of the building and not a deductible business ex- pense. — Art. 8, Reg. 33, Revised. If 1 25— Expense — Commissions Paid. Commissions paid in purchasing and selling securities are a part of the cost or selling price of the securities and not 221 INDIVIDUALS— Continued DEDUCTIONS— Expenses otherwise deductible. They do not constitute expense de- ductions in a return of income. — Art. 8, Reg. 33, Revised. 11120 — Expenses Incurred in Earning Income Not Subject to Tax. Expenses incurred in earning income, which is not subject to income tax do not constitute allowable deductions in com- puting net income from other sources which are taxable under the law. — Treasury Decision 2137. I1 127 — Expense Incurred Entertaining Prospective Customers. Amounts expended by a business man in entertaining out- of-town customers or prospective customers, can be claimed as deductions if the sole purpose of the business man in mak- ing such expenditures is to cultivate the good will of his customers and secure an increase in trade. — Primer, Ques- tion 63. If 128— Farm. Cost of stock purchased for resale is an allowable deduc- tion under the item of expense, but money expended for stock for breeding purposes is regarded as capital invested, and amounts so expended do not constitute allowable deduc- tions, except as hereinafter stated. — Art. 4, Reg. 33, Re- vised. 11128(a)- A person cultivating or operating a farm for recreation or pleasure, on a basis other than the recognized principles of commercial farming, the result of which is a continual loss from year to year, is not regarded as a farmer. In such cases if the expenses incurred in connection with the farm are in excess of the receipts therefrom, the entire receipts from the sale of products may be ignored in rendering a re- turn of income, and the expenses incurred being regarded as personal expenses, will not constitute allowable deduc- tions in the return of income derived from other sources. — Art. 4, Reg. 33, Revised. INDIVIDUALS— Continued DEDUCTIONS— Expenses 11128(b)- Amounts expended for the purpose of making a farm which is purchased in a run-down condition a profit-paying property, cannot be claimed as deductions, as the amounts so expended are held to be investments of capital, the result of which is an improvement or betterment, and until the farm becomes a paying proposition, no portion of the gross re- ceipts is to be reported as income and no portion of the ex- penses can be claimed as a deduction, either under the head of "Business Expenses" or under the head of "Losses." — Primer, Question 86. 11128(c)- If a crop which is ready to be harvested, but has not been sold, is destroyed by storm, flood, or fire, the value of that crop cannot be claimed as a deduction, but it is understood, of course, that the actual cost of producing or harvesting a crop which has been so destroyed may be claimed as a deduc- tion under the head of "Business Expense." — Primer, Ques- tion 89. 1[ 1 29 — Farm Employes Compensation. Where a taxpayer employs a man to assist in operating a farm and a woman to assist about the house, the amount paid to the male employe is allowed as a deduction in his return, but a line is drawn as to the amount paid to the female em- ploye. If her time is employed entirely in taking care of milk and cream produced for sale, in the production of but- ter, cheese, etc., the care of milk cans and churns, or, if a separate table is maintained for laborers employed on the farm and her services are used entirely in the preparation and serving of the meals furnished the laborers and in car- ing for their rooms, the compensation paid her constitutes an allowable deduction. If, however, she is employed to assist in caring for the farmer's own household, no deduction can be claimed. — Primer, Question 60. K 130— Farm Machinery. The cost of farm machinery is not an allowable deduction as an item of expense, but the cost of ordinary tools may be included under this item. — Art. 4, Reg. 33, Revised. 223 INDIVIDUALS— Continued DEDUCTIONS—Expenses Tf 130(a) — Farm Repair Expenses on a Rental Basis. Items of expense incurred and paid by a taxpayer during the calendar year in connection with a farm which is leased to another on a cash or crop-share rental basis, such as re- pairs to fences, farm buildings, etc., are allowable as deduc- tions. — Primer, Question 66. If 131 —Farm Stock. An individual engaged in raising and selling stock (cattle, sheep, horses, etc.), is not entitled to claim as a loss the value of such animals raised which die. The cost of raising will have been taken as an expense deduction. In the case of animals purchased, which die, the amount of purchase money will be an allowable deduction, if not previously de- ducted as a business expense. In case of sale the total amount received for stock raised and for stock purchased for resale is to be accounted for as income. — Art. 4, Reg. 33, Revised. ^ 132— Fees Earned, But Not Paid. A professional man earning a fee in 1917, which was never paid him, cannot claim such an amount as a deduction for the reason that it was never returned as income. — Primer, Question 96. ^ 1 33 — Income Tax — Amount Paid Not Deductible. * The Income Tax Law states that income taxes are not al- lowable as deductions. Under this provision income tax paid in 1918 on income received in 1917 or any previous year cannot be deducted. — Primer, Question 79. Tj 1 34 — Copyright and Plates — Investment of Capital in. Amounts expended for securing copyright and plates which remain in possession of and as property of the person making the payments, are investments of capital and can not be allowed as deductions in returns of income. — Art. 8, Reg. 33, Revised. ^ 1 35 — Titles to Property — Investment of Capital in. Cost of defending title or perfecting title to property, con- stitutes a part of the cost of the property and is not a busi- ness expense. — Art. 8, Reg. 33, Revised. 224 INDIVIDUALS— Continued DEDUCTIONS—Expenses If 1 36 — Partnerships, As Such, Are Not Taxable. For explanation, see "Partnerships" (see H 368.) ^ 1 37 — Premium on Fidelity Bond. Where an employe is required to furnish bond and pay the premium on such bond as a necessary incident of his employment, the premium on the bond will constitute an allowable deduction in computing net income. — Treasury Decision 2090. I1 1 38— Premiums on Life and Fire Insurance. Premiums paid for insurance on property which is not occupied by the owner as a dwelling, but is rented or leased to secure an income, constitute allowable deductions in com- puting net income. Premiums paid on life insurance policies by the insured do not constitute allowable deductions under the Income Tax Law. — Treasury Decision 2090. If 1 39 — Rent or Capital Investment. Where a leasehold is sold for a specified sum, the pur- chaser may take as a deduction in his return an aliquot part of such sum, each year, based on the number of years the lease has to run. ^ 1 40 — Rent for Residential Property. In the case of a professional man who rents a property for residential purposes but receives there, clients, patients, or callers in connection with his professional work (the place of business being elsewhere), no part of the rent is deductible as business expense. ^141 — Residential Property Used for Business Purposes. Where a physician, or other professional or business man rents a home and uses a portion of same for professional or business purposes, the proportion of the rent paid which is properly chargeable to the number of rooms so used may be claimed as a deduction. — Primer, Question 72. Tf 1 42^ — Salary in Conjunction With Room and Board. If an employer agrees to pay an employe a certain stipu- lated salary and furnish him with room and board, a fair 225 INDIVIDUALS— Continued DEDUCTIONS— Interest rental value is to be placed upon the room and upon the meals furnished, and their amounts reported as income by the employe. If the services of the employe are used in the employer's business or trade, the latter may claim the rent paid by him for the room, if any, and the actual cost of the meals so furnished as a deduction under the head of "Busi- ness Expenses." — Primer, Question 23. ^ 143 — Taxes Paid by Tenant to Landlord. Taxes paid by a tenant to a landlord are considered as additional payment for rent and are deductible as an expense of carrying on business. — Treasury Decision 2090. ^ 1 44 — Special Compensation to Employes. Special compensation to employes may be deducted from gross income if clearly shown that such payment is made for services rendered and is paid in pursuance of a contract ex- pressed or implied. Not deductible if so-called compensa- tion is a gratuity or voluntary payment. — Treasury Decision 2152. See If 38. ^ 1 45 — Wages or Salary Drawn From Own Business. Wages or salary drawn by a taxpayer from his own busi- ness are more in the nature of a charge out of profits than a charge against profits and therefore does not constitute an allowable deduction. If such could be deducted it would merely be added to his income, the effect of which would be to take money out of one pocket and put it in another. — Primer, Question 62. 11146— INTEREST. All interest paid or accrued within the taxable year on indebtedness, except on indebtedness incurred or continued to purchase or carry obligations or securities (other than obligations of the United States issued after September 24, 1917) , the interest upon which is wholly exempt from taxa- tion under this title as income, is deductible. — Law, page 62, Lines 8-20. INDIVIDUALS— Continued DEDUCTIONS— Taxes 14e(a) TAXES IMPOSED BY UNITED STATES, ITS POSSESSIONS AND FOREIGN COUNTRIES Following is a digest of the provisions of the provisions of the law and a summary of paragraphs 147 to 152, which follow : (1) Taxes imposed on citizens or residents of the United States by authority of the United States, Porto Rico and the Philippine Islands (EXCEPT INCOME, WAR-PROFITS AND EXCESS-PROFITS TAXES), are proper deductions from gross income. (2) Taxes assessed against local benefits are not proper deductions. (3) Taxes paid to a foreign government by a citizen or resident of the United States (except income, war-profits and excess-profits taxes), are proper deductions against gross income. (4) Income, war-profits and excess-profits taxes paid by a citizen of the United States to a foreign country, Porto Rico or the Philippine Islands may be deducted from the amount of income taxes for which he is liable under the Act. (5) Subjects of foreign countries residing in the United States may use as a credit income, war -profits and excess-profits taxes paid to Porto Rico and the Philippine Islands. (6) Subjects of foreign countries residing in the United States may deduct as a credit against taxes due in the United States income^ war- profits and excess-profits taxes providing the foreign country of which the resident is a subject allows citizens of the United States residing in such foreign country to deduct a similar credit. If 147— Taxes. Under the Revenue Act of 1918 the allowable deductions from gross income as taxes are as follows: ^ 1 48 — Taxes Imposed by Authority of the United States. (a) Taxes paid or accrued within the taxable year im- posed by the authority of the United States, except income, war-profits and excess-profits taxes. |] 1 49 — Taxes Imposed by Authority of Porto Rico and Philippine Islands. (b) With the exception of income, war-profits and excess- profits taxes, the amount of all taxes paid or accrued within the taxable year imposed by the authority of the govern- ments of Porto Rico and the Philippine Islands, or by any foreign government, are deductible from gross income. 227 INDIVIDUALS— Continued DEDUCTIONS— Taxes 11149(a)- A member of a partnership or a beneficiary of an estate or trust may deduct as a credit his proportionate share of such taxes so paid during the taxable year by the partner- ship or by the estate or trust. ^ 149(b)— It is important to emphasize that the income, excess- profits and war-profits taxes paid by a citizen or resident to a foreign country, or to Porto Rico or the Philippine Islands, are deductible as a credit, not from gross income, but from the total amount of income tax, computed under the pro- visions of the law for which a citizen or resident may be liable— See T[ 151. Thus, John Doe, who has paid an income or excess-profits tax to a foreign country of $500, computes his total Federal (U. S.) income taxes under the Revenue Act of 1918, at $3,000. Under the provisions of Section 222 (Credit for Taxes) he may deduct the $500 paid to a foreign country from the $3,000 taxes so computed, leaving his net tax liability $2,500. K 1 50— Taxes Imposed by the Authority of a State, Territory or Taxing Subdivision Thereof. (c) Taxes paid or accrued within the taxable year im- posed by the authority of any State or Territory or county, school district, municipality, or other taxing subdivision of any State or Territory are deductible from income. Such deductible taxes, however, do not include those assessed against local benefits. See U 157, 158. jf 1 51 — Taxes Paid to a Foreign Government. (d) Taxes paid or accrued within the year imposed upon a citizen or resident of the United States by the authority of any foreign country are deductible from gross income ex- cept the amount of income, war-profits and excess-profits taxes paid to any foreign country, the amount of which may be deducted by a citizen or resident from the amount of income taxes for which he is liable under the Act. See II 149 and 149(b). INDIVIDUALS— Continued DEDUCTIONS— Taxes H 1 52 — Foreign Taxes. In the case of a citizen of the United States, the amount of any income, war-profits and excess-profits taxes paid during the taxable year (See H 151) to any foreign country, upon income derived from sources therein, or to any pos- session of the United States ; and in the case of a resident of the United States, the amount of any such taxes paid dur- ing the taxable year to any possession of the United States. ^ 1 53 — Resident Aliens. In the case af an ahen resident of the United States who is a citizen or subject of a foreign country, the amount of any such taxes (income, war-profits and excess-profits taxes) paid during the year to such country, upon income derived from sources therein, may be deducted from the total amount of his taxes due to the United States, if such coun- try in imposing taxes allows a similar credit to citizens of the United States residing in such country; and in the case of any such individual who is a member of a partnership or a beneficiary of an estate or trust, his proportionate share of such taxes paid during the taxable year by the partner- ship or by the estate or trust to a foreign country or to any possession of the United States, as the case may be. —EXAMPLE. A resident alien of the United States who is a subject of England owns considerable real estate in the City of London and pays real estate taxes. These taxes are a proper deduction against gross income received from the United States and England. In addition to the real estate taxes he would the income derived from his real estate holdings, and this income and be obliged to pay to his own countiy income and excess -profits taxes on excess-profits tax imposed by England could not be deducted as a credit against his taxes due in the United States unless England allowed cit- izens of the United States residing in England to charge off a like credit for income and excess -profits taxes imposed by the United States. T1 1 54 — Partnerships. In the case of a member of a partnership where the partnership has already given credit to the partner for 239 INDIVIDUALS— Continued DEDUCTIONS—Taxes the amount of any taxes so paid in his behalf and the part- ner only accounts for the net amount received from the partnership, the partner must not again take credit for the taxes so paid as this would result in the taxpayers' having taken a double deduction. ^ 1 55 — Custom Duties. Custom duties paid during the year by an individual are allowable deductions as taxes or as part of the cost price, if the individual is engaged in the importation of goods and merchandise. U 156 — Inheritance Taxes. Inheritance taxes levied under the laws of a State and being a charge against the corpus of the estate are not allow- able as a deduction from income either to the estate or a beneficiary thereof. ]\ 1 57 — Local Benefits, Taxes Assessed Against. Taxes paid pursuant to assessments levied by special dis- tricts, such as irrigation, reclamation, drainage districts, etc., for sidewalks in cities, street extension, grading, pav- ing, etc., are held to be "taxes assessed against local bene- fits." Such taxes are not allowable deductions in a return of annual net income. — Treasury Decision 2090. See Law, page, 62, line 48. ^f 1 58 — Tax Assessments for Property Improvements. Taxes assessed against an individual on property owned by him to pay for the paving of a street contiguous to his property, the construction of a sewer, sidewalk, etc., the sprinkling or oiling of a street in front of his home, the con- struction of levees to protect, or ditches to drain property owned by him, cannot be claimed as deductions. In short, such taxes as are not general in nature and are levied on ac- count of some work or privilege the benefit of which accrues to a limited number of property owners, of which the tax- payer is one, are not allowable deductions. — Primer, Ques- tion 78. 230 INDIVIDUALS— Continued DEDUCTIONS— Taxes U 1 59 — State Tax Assessed on Capital Stock of Banks. Taxes on bank stock paid under legal requirement by the bank for its stockholders are deductible by the stockholders and not by the bank. Such payments are regarded as in the nature of additional dividends and a proportionate amount should be included by the stockholder in his dividends re- ceived and then claimed as a deduction under the heading of "Taxes."— Primer, Question 44; also Ar.t 8, Reg. 33, Re- vised. Where bank stock is sold and transferred between date of assessment and payment of the tax, in the absence of statute governing, the stockholder Hable for the tax (if the tax was actually paid) will have the benefit of the tax deduc- tion in return of income. This is a question of fact and to be determined as such.— Art. 8, Reg. 33, Revised. ^ leO— Taxes Paid by Tenant to Landlord. Taxes paid by tenant to a landlord are considered an ad- ditional payment for rent and are deductible as an expense of carrying on business. — Treasury Decision 2090. 1)161— Taxes (Other Than Excess-Profits) Deductible. AH taxes levied by the general taxing authority, levied and paid on all taxable subjects, including tax imposed and paid under the Revenue Act of 1917, except war-excess profits, income taxes, and taxes assessed against local bene- fits, are allowable deductions to the party paying the same. Although excess-profits tax paid is not an allowable deduc- tion in ascertaining the net income, the net income shown on any return will be credited with the amount of excess- profits tax for which the taxpayer will be liable for the same year, in order to determine the amount of income-tax liability. In the case of business, excise, license, or privilege taxes, they may be deducted either as taxes or items of expense, but not under both heads. — Art. 8, Reg. 33, Revised. 231 INDIVIDUALS— Continued DEDUCTIONS—Losses LOSSES. T1 1 82 — All Losses Deductible. Losses sustained during the taxable year, if not compen- sated by insurance or otherwise, are proper deductions in arriving at net income for the purposes of the tax whether such losses were incurred in the taxpayer's regular trade or business or whether they were incurred in transactions entered into for profit though not connected with the tax- payer's regular trade or business; also losses of property whether or not such property is connected with the tax- payer's regular trade or business. This is of especial interest to investors and brokers who have sustained losses in investment or speculative accounts. Non-resident aliens are allowed to deduct losses on trans- actions entered into for profit and not connected with trade or business only as to such transactions within the United States. ff 163— -Losses Defined. The Revenue Act of 1918 defines deductible losses as fol- lows: (a) Losses sustained during the taxable year and not compensated for by insurance or otherwsie, if incurred in trade or business. (b) Losses sustained during the taxable year and not compensated for by insurance or otherwise, if incurred in any transaction entered into for profit, though not connected with trade or business. In the case of a non-resident ahen individual, such loss is deductible only as to transactions within the United States. (c) Losses sustained during the taxable year of property not connected with the trade or business if arising from fires, storms, shipwreck or other casualty, or from theft, and if not compensated by insurance or otherwise. In the case of a non-resident alien individual, such loss is deduct- ible only on property within the United States. INDIVIDUALS— Continued DEDUCTIONS— Losses ^ 1 64 — Losses of Property or From Sale of Property. For the purpose of ascertaining the loss sustained from the sale or loss of property, real, personal, or mixed, ac- quired before March 1, 1913, the fair market price or value of such property as of March 1, 1913, shall be the basis for determining the amount of such loss sustained. Losses not compensated for by insurance or otherwise, are easily ascertained, and there would not appear to be any chance of erroneous construction as to these. ^1 1 65— Losses by Fire in Standing Timber. The actual amount of capital invested in standing timber, if acquired on or after March 1, 1913, and later destroyed by fire, may be claimed as a deduction if not reimbursed by in- surance or otherwise. If the timber was acquired prior to March 1, 1913, its fair market price or value as of that date may be claimed. To illustrate the methods to be employed in computing the amount of loss allowable as a deduction the following is submitted : A tract of land was acquired prior to March 1, 1913, and the estimated amount of timber stand- ing on that tract on that date was 1,000,000 feet, board measure, the fair market price or value per 1,000 feet, estab- lished by the current prices prevailing in the locality of the tract in question as of March 1, 1913, being $4. During the year 1917, 400,000 feet of this timber was destroyed by fire. In this case $1,600 is the amount which may be claimed as a deduction. — Primer, Question 87. Tj 1 66 — Loss From Reduction in Value of Inventory — Rebates. (a) At the time of filing return for the taxable year 1918 a taxpayer may file a claim in abatement based on the fact that he has sustained a substantial loss (whether or not actually reahzed by sale or other disposition) resulting from any material reduction (not due to temporary fluctuation) of the value of the inventory for such taxable year, or from the actual payment after the close of such taxable year of rebates in pursuance of contracts entered into during such year upon sales made during such year. In such case pay- ment of the amount of the tax covered by such claim shall 233 INDIVIDUALS— Continued DEDUCTIONS— Losses not be required until the claim is decided, but the taxpayer shall accompany his claim, with a bond in double the amount of the tax covered by the claim, with sureties satisfactory to the Commissioner, conditioned for the payment of any part of such tax found to be due, with interest. If any part of such claim is disallowed then the remainder of the tax due shall on notice and demand by the collector be paid by the taxpayer with interest at the rate of 1 per centum per month from the time the tax would have been due had no such claim been filed. If it is shown to the satisfaction of the Commissioner that such substantial loss has been sus- tained, then in computing the tax imposed by this title the amount of such loss shall be deducted from the net income. (b) If no such claim is filed, but it is shown to the satisfac- tion of the Commissioner that during the taxable year 1919 the taxpayer has sustained a substantial loss of the charac- ter above described, then the amount of such loss shall be deducted from the net income from the taxable year 1918 and the tax imposed by this title for such year shall be re- determined accordingly. Any amount found to be due to the taxpayer upon the basis of such redetermination shall be credited or refunded to the taxpayer in accordance with the provisions of Section 252. — See Law, page 85, line 55. ^ 1 68 — Loss Does Not Include Any Element of Depreciation. In determining the amount of deductible losses allowable to individuals and foreign and domestic corporations, the loss considered has in it no element of "depreciation" or "al- lowance for wear and tear," or "compensation from insur- ance or otherwise." It is to be such loss as is absolute and complete and which has been actually sustained. — Treasury Decision 2005. 11169 — Depreciation. Depreciation to cover exhaustion, wear and tear, and obso- lescence, as an allowable deduction has been separately pro- vided for, and is not to be confused with loss. — See U 185. 234 INDIVIDUALS— Continued DEDUCTIONS— Losses If 1 70 — Bonds and Similar Securities Written Off at the Direction of the Comptroller of the Currency. The fact that bonds or similar securities were written off at the direction of the Comptroller of the Currency or State banking department is not material. A mere book entry does not constitute either a loss or a gain for the purpose of the income tax. The fact that bonds were written off does not necessarily imply that they are a total loss, nor is this act conclusive proof that any loss occurred during the year for which return was made. Losses of this character are only ascertainable when the securities mature, are disposed of, or cancelled. — Art. 148, Reg. 33, Revised. ]f 1 71 — Loss or Depreciation Through Amortization of Bonds. This item is covered by H 204. ^ 1 7Z — Losses on District Irrigation Bonds. District irrigation bonds, as a rule, if not always, are a lien upon the real estate affected by the irrigation project, and until the corporation has taken such steps as are neces- sary to protect its rights and enforce the collection of the bonds, it does not appear that the corporation would be war- ranted in writing out of its assets and deducting from in- come, as a loss, the face value or any other arbitrarily ascertained amount representing a loss or shrinkage in value of such bonds. ^ 1 73 — Assessment on Stock. Assessments made by a corporation on its capital stock are regarded as further investments of capital and do not constitute an allowable deduction in the return of the indi- vidual. But in the case of a shareholder in an irrigation company where the purpose of the assessment is merely to raise funds to keep the irrigation system in usable condition and not to make extensions or betterments, the amount as- sessed against each shareholder may be claimed as deduc- tion. — Primer, Questions 70 and 71. 235 INDIVIDUALS— Continued DEDUCTIONS— Losses If 174— Loss— Good Will. Good will does not represent a value attaching to physical property. It is held to be an intangible asset whose value, separate and apart from the business with which it is con- nected, is not acapable of determination. For the purpose of income tax it is capable of neither appreciation nor deprecia- tion. An amount claimed to represent its decline in value is not an allowable deduction from gross income in computing the tax liability of an individual or corporation. — Art. 8, Reg. 33, Revised. T1 1 75 — Inventories. Whenever in the opinion of the Commissioner the use of inventories is necessary in order clearly to determine the income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income. 11176— Bad Debts. (Law, page 54, line 51.) There may be deducted from income all debts due to the taxpayer actually ascertained to be worthless and charged off within the taxable year. — Law, page 63, line 9. In order that a debt may be claimed as a deduction, it must be (a) a bona fide debt, (b) definitely ascertained to be worthless and uncollectible during the year for which the deduction is claimed, and (c) if books are kept it must be charged off within the year for which the deduction is claimed and no longer considered an asset or carried as such on the books. — Primer, Question 90. \\ 1 77 — Bad Debts — Compromise. Where an indebtedness is claimed and contested and a settlement is had by way of compromise whereby an amount, less than the debt claimed, is accepted in full pay- ment and satisfaction of the debt, the difference between the amount paid and that claimed is not allowable as a deduction for bad debts. Where the settlement in compromise con- 236 INDIVIDUALS— Continued DEDUCTIONS— Losses sists of a promise to pay an amount less than the debt claimed, the amount promised to be paid forms the basis of a new transaction, and upon failure to make good this prom.- ise the question will arise as to the deductibility of the new amount only. |[ 178— Bad Debts— Further Definition. Where all of the surrounding and attendant circumstances indicate that a debt is worthless and uncollectible and that legal action to enforce payment would in all probability not result in the satisfaction of execution on a judgment, a showing of these facts will be sufficient showing of the worthlessness of the debt for purposes of deduction. In a case where " A " indorses a note for " B " and the latter has departed for parts unknown when the note be- comes due in 1918 and " A " is required to make good his indorsement, if he has no knowledge of " B*s '' present whereabouts and has good reason to believe that he is pos- sessed of no assets and that it is his intention never to make payment, the amount so paid by " A " may be considered a bad debt due him from " B ". — Primer, Question 93. In the case where a taxpayer advances a certain sum to a needy friend or relative with good reasons for believing that the advance will never be returned, such amount cannot be claimed as a deduction; partaking as it does somewhat of the nature of a philanthropic donation or a goodwill offering, it is not held to constitute a bona fide debt. — Primer, Ques- tion 94. ^ 1 79— Bad Debts Arising From Unpaid Wages, Salaries, Rents, Etc. Debts arising from unpaid wages, salaries, rents, and items of similar taxable income will not be allowed as a de- duction, unless the income they represent has been included in the return of gross income for the year in which the de- duction as a bad debt is sought to be made, or in a previous year, and the debts themselves have been actually ascer- tained to be worthless and charged off. 237 INDIVIDUALS— Continued DEDUCTIONS— Losses If 180 — Bad Debts — Bankruptcy. Bankruptcy may or may not be an indication of worth- lessness of a debt. Actual determination of worthlessness in such cases is possible only when settlement in bankruptcy shall have been had. Only the difference between the amount received in distribution of assets of the bankrupt and the amount of proved claim may be considered for the purpose of deduction as a bad debt. An amount loaned to a corporation or firm which has be- come bankrupt cannot be claimed as a deduction unless the affairs of the debtor have been fully adjusted, its assets sold for the benefit of, or distributed to, its creditors, and its re- ceiver in bankruptcy discharged. If all this has occurred during the year 1918, so much of the debt as remains un- paid after the receiver is discharged may be claimed as a deduction for the year 1918. But it is not necessary that a corporation or firm be declared a bankrupt before the amount is claimed as a deduction. If the debtor corporation has no assets whatsoever, and it is definitely known that nothing whatsoever can be collected from debtor itself or any person connected with it, a creditor need not go to the expense of instituting bankruptcy proceedings in order to es- tablish his right to claim the worthless debt as a deduction. — Primer, Questions 91 and 92. ^ 1 81 — Bad Debts — ^Foreclosure Sale on a Mortgage. Where, under foreclosure, a mortgagee buys in the mort- gaged property and credits the indebtedness with the pur- chase price, the difference between purchase price and the indebtedness will not be allowable as a deduction for bad debt — the property which was security for the debt being in possession and ownership of the mortgagee is, for the pur- poses of income tax, held to be sufficient to justify a disal- lowance of a claim for bad debt. Only where purchaser for less than debt is another than mortgagee may the difference between debt and net from sale credited be deducted as bad debt. — Art. 8, Reg. 33, Revised. 238 INDIVIDUALS— Cont'd DEDUCTIONS— Depreciation I1 182— Debts Due Prior to March 1, 1913. All debts representing amounts that became due and payable prior to March 1, 1913, and not ascertained to be worthless prior to that date, whether representing income or a return of capital, are held to be allowable deductions . . . in a return of income for the year in which they are actually ascertained to be worthless and are charged off. — Treasury Decision 2224. 1(183- Bad Debts— Income if Collected. Bad debts which have been claimed and allowed as a de- duction in prior returns are considered income if subse- quently collected. — Art. 4, Reg. 33, Revised. Where a taxpayer in rendering his 1914 return claimed a deduction to cover a debt then believed to be absolutely worthless and in 1918 the debtor has discharged part of his obligation, the amount should be considered as an item of income and included under " Gross Income ** in the 1918 re- turn. — Primer, Question 95. Tf 1 84 — Default on Installment Payments. See n 44, 45, 46. ^85- DEPRECIATION, DEPLETION AND AMORTIZATION. A reasonable deduction may be made for the exhaustion, wear and tear, and obsolescence, of property arising out of its use or employment in the business or trade. — Law, page 63, line 11. As the rate at which depreciation may be claimed is de- pendent, in a greater or less extent, upon local conditions, the use to which the property is put, and its probable life- time under normal business conditions, no specific rates at which it may be claimed have ever been established. The law states that a " reasonable allowance " may be claimed and it is for the taxpayer to determine what constitutes a " reasonable allowance." To compute the amount which may be claimed, a taxpayer should determine the probable lifetime of the property, then divide its cost to him by the 239 INDIVIDUALS— Con^d DEDUCTIONS— Depreciation number of years it will be usable in a business in which employed, and the result thus obtained will represent the amount which may be claimed each year as a deduction, e. g., a frame building, the probable lifetime of which, with- out repair or replacement, is 25 years, cost $5,000. Divide $5,000 by 25 and claim $200 each year as depreciation. Tjise- While each taxpayer must determine the probable lifetime of his property without regard to the following figures, it has been estimated that the average usable lifetime of a frame building is 25 years; a brick building, 35 years; a stone building or a steel and concrete building, 50 to 100 years. The estimated lifetime of ordinary machinery is 10 years; that of automobiles used for business or farm pur- poses and farm tractors, 4 to 5 years. 11187- If a taxpayer wishes to claim the full amount of depreci- ation estimated to have occurred in the value of a building, or other property used for business or trade purposes, he may do so, but this precludes his claiming a deduction to cover any amount expended during the same year in making repairs. If he wishes to claim a deduction on account of re- pairs, their cost must be deducted from the full amount of depreciation, and the balance may then be claimed as a deduction under the heading of " Depreciation " ; that is, if a taxpayer expends $100 in making repairs to a building which will depreciate in value $200 during the calendar year he may claim $100 as a business expense and $100 as depreci- ation, or he may claim $200 as depreciation and nothing for repairs. In short, the aggregate deductions claimed on ac- count of repairs and depreciation must not exceed the full amount of depreciation estimated to hav(B occurred. (Note. — The repairs referred to in the above paragraph are such as are general in character, representing replace- ments, etc. Small items, such as replacement of broken window panes, papering, minor repairs, etc., are allowable, even though full amount of depreciation ha^ been claimed.) 240 INDIVIDUALS— Cont'd DEDUCTIONS—Depreciation 11188- In claiming depreciation the following fundamental prin- ciples must be taken into consideration : 11189- (a) Only such depreciation as results from exhaustion, wear and tear, and obsolescence, of property, arising out of its use or employment in business or trade, can be claimed. Depreciation in the value of a home or any article of prop- erty, such as automobiles, used for personal pleasure or con- venience, cannot be claimed ; the property must be used for the purpose of producing income. 11190- (b) Depreciation other than that arising from wear and tear, such as a lessening of values due to changes in the so- cial or business conditions in the neighborhood in which a property is located, changes of street grade, of fluctuations in market values, etc., cannot be claimed. 11191- (c) Depreciation in the value of land, whether improved or unimproved, due to ordinary erosion, exhaustion, or any other cause cannot be claimed. 11192- (d) Where the value of a piece of machinery or any other asset is lessened by reason of the production of an improved machine or article, that depreciation cannot be claimed, as it does not result from exhaustion, v/ear and tear. (e) Where, in the course of years, the owner of property has claimed its full cost as depreciation in his income tax returns, no further claim will be allowed. 11194- (f ) The value to be cared for by depreciation is the actual amount invested in the property and not the value which may be ai'bitrarily or otherwise fixed. — Primer, Question 99. 241 INDIVIDUALS— Cont'd DEDUCTIONS— Depreciation Losses due to the voluntary removal or destruction of buildings, etc., incident to improvements are either a proper charge to the cost of new additions or to depreciation already provided, as the facts may indicate, but in no case is it a proper deduction in determining net income. If, however, a building is destroyed prior to the close of its lifetime, as estimated for the purposes of making depreciation charges, that portion of its cost which is properly chargeable to the period it might have remained in a usable condition may be considered a part of the cost of the new building when com- puting the amount of the gain or profit derived from a sale of the latter. — Prim.er, Question 100. 11196- If the authorities of a municipality declare that a building is unsanitary or unsafe for the purposes to which put and its destruction is ordered, the losses sustained by the owner cannot be claimed either as a loss or as depreciation. — Primer, Question 101. I1 1 97 — Amortization. In the case of buildings, machinery, equipment, or other facilities, constructed, erected, installed, or acquired, on or after April 6, 1917, for the production of articles con- tributing to the prosecution of the present war, and in the case of vessels constructed or acquired on or after such date for the transportation of articles or men contributing to the prosecution of the present war, there shall be allowed a reasonable deduction for the amortization of such part of the cost of such f acihties or vessels as has been borne by the taxpayer, but not again including any amount otherwise allowed under this title or previous Acts of Congress as a deduction in computing net income. At any time within three years after the termination of the present war the Commissioner may, and at the request of the taxpayer shall, re-examine the return, and if he then finds as a re- sult of an appraisal or from other evidence that the deduc- 243 INDIVIDUALS— Cont'd DEDUCTIONS— Depreciation tion originally allowed was incorrect, the taxes imposed by this title and by Title III for the' year or years affected shall be redetermined ; and the amount of tax due upon such re- determination, if any, shall be paid upon notice and demand by the collector, or the amount of tax overpaid, if any, shall be credited or refunded to the taxpayer in accordance with the provisions of Section 252. If 1 98 — Oil and Gas Wells, Mines, Other Natural Deposits and Timber — Depletion and Depreciation of. In the case of mines, oil and gas wells, other natural de- posits, and timber, a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar conditions in each case, based upon cost including cost of development not otherwise deducted, is allowed. In de- termining cost, the fair market value as of March 1, 1913, will be representative for property acquired prior to that date and the actual cost if acquired subsequent to March 1, 1913. Mines, oil and gas wells, discovered by the taxpayer by prospecting and exploration after March 1, 1913, the fair market value of which is materially disproportionate to the actual cost, the depletion allowance shall be based on the fair market value of the property at the date of dis- covery, or within 30 days thereafter. The deductions provided in the above paragraph must be computed under regulations prescribed by the Commissioner of Internal Revenue. In the case of leases, the deduction shall be equitably apportioned between the lessor and lessee. ![i9a— The value of mines as of March 1, 1913, must be deter- mined upon the salable value en bloc. 11200— This value (en bloc) having been ascertained, the num- ber of units (tons, pounds, etc.) should be made. The en bloc value, divided by the estimated number of units in the mine, will determine the per unit value, which, multiplied by the number of units mined and sold during any one year, 243 INDIVIDUALS— Cont^d DEDUCTIONS—Depreciation will determine the sum which will constitute an allowable deduction from the gross income of that year on account of depletion. — Treasury Decision 2446. 11201 — The value to be cared for by depreciation is the actual amount invested in the property and not the value which may be arbitrarily or otherwise fixed. — Art. 8, Reg. 33, Revised. If 202 — Depreciation Not to Be Confused with Loss. Depreciation as an allowable deduction in ascertaining net income is not to be confused with loss. ^ 203 — Book Values Not a Basis for Determining Depreciation. Book values which reflect a shrinkage in the value of assets are not a basis for determining taxable income. — Treasury Decision 2090. Likewise and conversely any appreciation in the value of assets due to an adjustment or appraisal and entered upon the books of the individual or corporation is held not to be income until such increase in value has been converted into cash or its equivalent. Hence in the preparation of re- turns mere book entries of appreciation in the value of cap- ital assets will be disregarded. — See also T[ 205. jf 204 — Amortization of Bonds. The original regulations (Art. 135) were revised and par- tially revoked by Treasury Decision 2005, which holds, in effect, that neither increase nor shrinkage in book values, due to market fluctuations or otherwise, is to be taken into account in making returns of annual net income. By the amended ruling (Treasury Decision 2161) corporations hold- ing bonds which were purchased above , ar and proportion- ately reducing the value of those bon^^s each year, are no longer permitted to deduct such depreciation in a return of income. In the case, however, of corporations selling their own bonds at a discount, such discount, under conditions shown in Art. 135, as revised, may be prorated over the life ^ 244 INDIVIDUALS— Cont^d DEDUCTIONS— Depreciation of the bonds and an aliquot part deducted from gross income each year. H 205 — Depreciation in Book Values of Securities. Depreciation in book values of bonds and similar securities written down at direction of Comptroller of Currency are not allowable, but Section 203 of the present Act provides that, whenever in the opinion of the Commissioner of In- ternal Revenue it is considered necessary in order to reflect the true income, the taxpayer must take an inventory under rules and regulations prescribed by the Commissioner, and in such a manner as conforms as nearly as possible to the best accounting practice in the trade or business most clearly disclosing the correct income. This section provides further that if the taxpayer con- siders that he has sustained a loss resulting from a reduc- tion in the value of the inventory for the taxable year, either before the time of filing or subsequently, he may present a claim for abatement or refund in the amount of such loss ; and if the evidence submitted proves satisfactory to the Commissioner the amount of the loss so claimed shall be credited or refunded. Under the previous Act the Commissioner ruled, with the approval of the Attorney General, that dealers in securities were allowed the privilege of inventorying securities either at cost or market value whichever was lowest. It is problem- atical whether this ruling will be made applicable to the present Act on account of the unusual fluctuation of market values due to the termination of the present war. ^ 206 — Depreciation in Value of Patents. If a taxpayer buys a patent for $5,000 which, under the patent laws of the United States, had five years yet to run, and the value of this patent depreciates each year on account of the exhaustion of the patent period, the cost of the patent divided by the number of years it has yet to run yields an amount which may be claimed each year as depreciation. In this case the amount is $1,000. — Primer, Question 102. 245 INDIVIDUALS— Cont'd DEDUCTIONS— Depreciation II 207 — Depreciation in Value of Stage Costumes. If costumes purchased by actors and actresses are used exclusively in the production of a play, and are not adapted for occasional personal use and are not so used, a deduction may be claimed on account of such depreciation in their value as occurs during the year on account of wear and tear arising from their use in the productions of the play or to their becoming obselete at the close of the production. — Treasury Decision 2090. TI 208 — Depreciation — Farm Buildings. Provision is made for "a reasonable allowance for the ex- haustion, wear and tear of property arising out of its use or employment * * *," there may be claimed a reasonable allowance for depreciation on farm buildings (other than a dwelling occupied by the owner) , farm machinery, and other physical property, including stock purchased for breeding purposes, but no claim for depreciation on stock raised or purchased for resale will be allowed. II 209 — Depreciation — Real Estate. Real estate, as such, and as distinct from the improve- ments thereon, is not reduced in value by reason of wear and tear, and it therefore follows that the "allowance" contem- plated by depreciation in the case of real estate corporations does not apply to the ground, but is intended to measure the decline in the measure of improvements, which decline in value is due to wear and tear of such improvements. — Treasury Decision 2137. 11 21 — Fiduciary — Depreciation. Depreciation is not allowed fiduciaries as a deduction from gross income in cases where no depreciation reserve is maintained, but the amount claimed as a deduction is paid to the beneficiary as income. — ^Treasury Decision 2267. H 211.— Depreciation of Good Will. Capable neither of appreciation nor depreciation. Amount claimed as decline in value of, not allowable to either indi- vidual or corporation. — Treasury Decision 2131. See 1[ 174. 246 INDIVIDUALS— Continued DEDUCTIONS fl 212 — Contributions. Contributions or gifts made within the taxable year to corporations organized and operated exclusively for religi- ous, charitable, scientific, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private stockholder or individual, or to the special fund for voca- tional rehabilitation as authorized by Section 7 of the Voca- tional Rehabilitation Act, to an amount not in excess of 15 per centum of the taxpayer's net income as computed with- out the benefit of this paragraph. Such contributions or gifts shall be allowable as deductions only if verified under rules and regulations prescribed by the Commissioner, with the approval of the Secretary. In the case of a non-resident alien individual, this deduction shall be allowed only as to contributions or gifts made to domestic corporations or to such vocational rehabilitation fund. — Law — page 64, line 4, ^ Contributions made by individuals to such organizations as the American Red Cross, Knights of Columbus, Y. M. C. A., Salvation Army and similar organizations are de- ductible under the provisions of Section 214 (11). There is much doubt, however, if, under the Act, corpora- tions are permitted to deduct the amount of such contribu- tions. They were not permitted to do so under the previous law. This doubt will likely soon be cleared up by a Treasury ruling. In connection with claim for the above deduction of con- tributions on returns of income there shall be stated : (a) The name and address of each organization to which a gift was made. (b) The date and amount of the gift in each case. Where the gift is other than money, the basis for calcula- tion of the value of the gift shall be the fair market value of the property the subject of gift at the time of the gift. — Art. 8, Reg. 33, Revised. 247 INDIVIDUALS— Cont'd PERSONAL EXEMPTION ^ 21 3 — Amounts Received as Dividends. For the purpose of the normal tax only, the income embraced in a personal return shall be credited with the amount received as dividends upon the stock or from the net earnings of any corporation, joint-stock company or associa- tion, trustee, or insurance company, which is taxable upon its net income as hereinafter provided, and with the amount received as dividends from a personal service corporation out of earnings or profits upon which income tax has been imposed by Act of Congress — Law, page 65, line 30. |[214 — Dividends — State Taxes on Bank Stock. State taxes on capital stock of banks, paid by banks are assessed against the individual stockholder and constitute an allowable deduction in the return of such individual. The individual should include his proportionate share of such taxes in his return as income and then claim the amount as a deduction under the heading "Taxes." — Primer, Question 44 ; also Art. 8, Reg. 33, Revised. ^ 21 5 — Amounts Received as Interest. The amount received as interest upon obligations of the United States, and upon bonds issued by the War Finance Corporation is exempt from normal tax. 11216— PERSONAL EXEMPTION. For the purpose of the normal tax only the law allows as an exemption in the nature of a deduction from net income the sum of $1,000 for an unmarried person not the head of a family, and $1,000 additional, or $2,000 in the case of 1. The head of a family, whether married or not. 2. A married man with wife living with him. 3. A married woman with husband living with her. 11217- (4) $200 for each person (other than husband or wife) dependent upon and receiving his chief support from the taxpayer, if such dependent person is under 18 years of 248 INDIVIDUALS— Cont'd PERSONAL EXEMPTION age or is incapable of self-support because mentally or phys- ically defective. For further explanation of the status of husband and wife under the law, see H 226 to H 242. 11218- A citizen or resident of the United States may secure the benefit of personal exemption to which he is entitled when receiving a payment of Interest on bonds containing so- called " tax-free " or " no-deduction " clause by attaching to the interest coupons an income-tax exemption certificate, Form 1001, Revised. If exemption is not desired, Form 1000, Revised, should be used. — Primer, Question 129. If 219 — Head of a Family — Definition. The head of a family is held to be a person who is the chief support of one or more individuals who are closely con- nected with him by blood relationship, relationship by mar- riage or by adoption and whose right to exercise family control and provide for these dependent individuals is based upon some moral or legal obligation. The head of a family shall be allowed an additional ex- emption of $200 for each person (other than husband or wife) dependent upon and receiving his chief support from the taxpayer, if such dependent person is under 18 years of age or is incapable of self-support because mentally or phys- ically defective. ^ 220 — Guardians and Trustees. Guardians or trustees are allowed to make this personal exemption as to income derived from the property of which such guardian or trustee has charge in favor of each ward or cestui que trust. In no event shall a ward or cestui que trust be allowed a greater personal exemption than a single individual. 11221 — Estates of Deceased Persons. There shall be allowed an exemption from the amount of net income of estates of deceased citizens or residents of the United States during the period of administration or settle- 249 INDIVIDUALS— Continued ment, and of trust or other estates of citizens or residents of the United States, the income of which is not distributed annually or regularly, the sum of $1,000, including such de- ductions as allowed. ff 222—Husband and Wife. See H's 226 to 242 for further information as to the status of husband and wife under the law. For the year 1913 the tax was computed from March 1, when the Act became effective, to December 31. Ten- twelfths of the specific exemptions and deductions were allowed. tf 223— Intent of the Law. The intent and purpose of the Income Tax Law is that all gains, profits, and income of a taxable class shall be charged and assessed with the corresponding income tax, normal and additional, and such tax shall be paid by the owner of such income or the proper representative thereof having the re- ceipt, custody, control, or disposal of the same. In any case where the conditions which obtain do not appear to fall within the law and regulations for the assessment and col- lection of the income tax, the proper tax shall be assessed in the particular case by the Commissioner of Internal Revenue upon his findings concerning the same. Ownership of in- come and liability for tax thereon shall be determined as of the year for which the return is required to be rendered. — Art. 49, Reg. 33, Revised. Tf 224— Record to be Kept. Every individual, partnership, corporation, or association liable to any tax imposed under the internal revenue laws of the United States or for the collection thereof, shall keep such records and render such statements and return, under oath, as shall be prescribed by the Commissioner of Internal Revenue. — Art. 50, Reg. 33, Revised. Tl 225 — Tax Withheld at Source Credit Against Income Tax. Income upon which any tax is required to be withheld at the source under this section shall be included in the return 250 INDIVIDUALS— Continued HUSBAND AND WIFE of the recipient of such income, but any amount of tax so withheld shall be credited against the amount of income tax as computed in such return. If 226— HUSBAND AND WIFE. If the combined income of husband and wife, living to- gether, and dependent children equaled or exceeded $2,000, all such income must be reported, either on one return or on separate returns. Husband and wife should make sepa- rate returns if either is subject to the surtax. The addi- tional or surtax imposed by the act will be computed on the basis of the separate income of each individual; that is, on the amount of each individual's income in excess of the minimum amount upon which the surtax at the grad- uated rates is to be calculated. ^ 227 — When Exemption Exceeds Net Income. Personal exemptions from tax are granted in respect of the normal income tax only. Where the total of allowable exemptions and credits exceeds the amount of net income, the excess of such exemptions may not be availed of as against the additional tax. — Art. 14, Reg. 33, Revised. II 228 — When Living Apart. Every single person and every married person not living with husband or wife in the sense below defined, who has a net income exceeeding $1,000 per annum, is liable to pay the normal tax under the law, but in making return for such tax such person may claim an exemption of $1,000 from his or her total net income. U 229 — When Living Together. Husband and wife living together are entitled to an ex- emption of $2,000 and $200 additional for each person (other than husband or wife) dependent upon and receiving his chief support from the taxpayer, if such dependent person 351 INDIVIDUALS— Continued HUSBAND AND WIFE is under eighteen years of age or is incapable of self -support because mentally or physically defective. ^ 230 — ^When Separated and Living Apart. However, when the husband and wife are separated and living permanently apart from each other each shall be en- titled to an exemption of $1,000. 11 231 — Husband and Wife Filing Separate Returns. Where husband and wife file separate returns of income, one of them being filed in time and the other delinquent, such returns are not supplemental of each other and de- linquency must be answered for by the one in connection with whose return it occurred. — Art. 26, Reg. 33, Revised. If 232 — Living Apart — Exemption. A husband who has a wife and children whom he sup- ports, but who is living apart from his wife under an agree- ment to do so, there being no judicial decree of separation, is entitled only to the specific exemption of $1,000. — Treas- ury Decision 2692: TI 233 — When Nnt Living Apart, But Having Separate Estates. If the husband and wife not living apart have separate estates, the income from both may be made on one return, but the amount of income of each, and the full name and address of both, must be shown in such return. II 234— Husband Should Make Return for Both. The husband, as the head and legal representative of the household and general custodian of its income, should make and render the return of the aggregate income of himself and wife, and for the purpose of levying the income tax it is assumed that he can ascertain the total amount of said income. H 235— When Wife Has Separate Estate Managed by Herself. If a wife has a separate estate managed by herself as her own separate property and receives an income of $1,000 or INDIVIDUALS—Continued HUSBAND AND WIFE over, she may make return of her own income, and if the husband has other net income, making the aggregate of both incomes more than $2,000, the wife's return should be attached to the return of her husband, or his income should be included in her return, in order that a deduction of $2,000 may be made from the aggregate of both incomes. The tax in such case, however, will be imposed only upon so much of the aggregate income of both as shall exceed $2,000. If 236— When Either Has an Income of $1,000 or Over. If either husband or wife separately has an income equal to or in excess of $1,000, a return of annual net income is required under the law, and such return must include the income of both, and in such case the return must be made, even though the combined income of both be less than $2,000. ^ 237— When Income of Both Is in Excess of $2,000. If the aggregate net income of both exceeds $2,000, an annual returji of their combined incomes must be made in the manner stated, although neither one separately may have an income of $2,000 per annum. They are jointly and separately liable for such return and for the payment of the tax. ^ 23d — When Either Dies During the Year. Where either dies during the year having a net taxable income of $1,000 or more, a return should be made by the executor or administrator of the deceased as of the date of his death, and the executor or administrator may claim an exemption of $2,000. The survivor, when making a return at the end of the year for the entire year, will be allowed the applicable exemption for the single or married status existing at the close of the year. — ^Treasury Decision 2090. ^ 239 — Deceased Husband — Amount of Specific Exemption Allowed. If the income of a deceased husband during the taxable year in which he died necessitates the filing of a return the specific exemption of $2,000 should be claimed. 253 INDIVIDUALS— Continued RETURNS ^ 240 — Income of Wife From Sale of Special (Magazine) Articles. Unless the wife has a separate estate which requires her to file a separate return of income or to join with her hus- band in a return which shall set forth her income separately, a husband having a taxable income of his own should in- clude in his return the income accruing to his wife from the sale of special magazine articles. If neither has an income of $1,000 or more, but together they have an aggregate in- come exceeding $2,000, a return of the joint income is re- quired to be filed by either the husband or wife, and the income derived by the wife as above set forth should be included in such return. The actual proceeds coming into the wife's possession during the tax year constitute the income to be included, and not the amounts estimated prior to publication and payment. — Treasury Decision 2135. ^241 — Single or Married Status — When Determined. The single or married status of the person claiming the specific exemption shall be determined as of the time of claiming such exemption if such claim be made within the year for which return is made, otherwise the status at the close of the year. If 242 — ^When an American Woman Marries a Foreigner. An American woman who marries a foreigner takes the nationality of her husband and cannot claim personal exemption. — Treasury Decision 2090. ANNUAL RETURNS OF INDIVIDUALS. 11 243— Who Shall Make Returns and When Returns Shall Be Made. Every person having a net income for the taxable year of $1,000 or over, if single, or if married and not living with husband or wife ; or of $2,000 or over if married and living with husband or wife, shall make under oath a return on or before March 15, 1919, for the year 1918, stating specfi- cally the items of his gross income and the deductions and credits allowed by this title. If a husband and wife living 854 INDIVIDUALS— Continued ' RETURNS together have an aggregate net income of $2,000 or over, each shall make such a return on or before March 15, 1919, for the year 1918, unless the income of each is included in a single joint return. Returns filed on the basis of a fiscal year shall be made on or before the fifteenth day of the third month following the close of the fiscal year. If the taxpayer is unable to make his own return, the re- turn shall be made by a duly authorized agent or by the guardian or other person charged with the care of the per- son or property of such taxpayer. If by reason of illness, absence, or non-residence a tax- payer is unable personally to render his return, he may appoint an agent to act for him, and the return executed by the agent will be accepted if he makes affidavit that he has sufficient knowledge to make a complete and accurate re- turn for his principal and assumes responsibility for making the return and incurring the penalties provided for a de- linquent, erroneous, false, or fraudulent return. — Primer, Question 6. 11243(a)— Forms of returns are provided by the Commissioner of Internal Revenue, and are to be had from the collectors of internal revenue of the several collection districts. — ^Art. 23, Reg. 33, Revised. [The various forms of return prescribed for the present Act will be treated in a supplement to this book as soon as they become available.] If 244 — Return Made and Mailed in Time. If a return is made and placed in the United States mail, properly addressed, and postage paid, in ample time, in due course of mail, to reach the office of the collector or deputy collector on or before the last due date, no penalty will be held to attach should the return not be actually received by such officer until subsequent to that date. — Art. 52, Reg. 33, Revised. H 245 — Dividends to Be Included in Annual Return. In every return shall be included the income derived from dividends on the capital stock, or from the net earnings of 255 INDIVIDUALS— Continued RETURNS any corporation, etc., except that in the case of non-resident aliens, such income derived from sources without the United States shall not be included. Tf 246 — Period Covered by Return. Jan. 1 to Dec. 31, 1918, and each calendar year thereafter, unless fiscal year has been designated. Tf 247 — Changing from Fiscal Year to Calendar Year. If a taxpayer, with the approval of the Commissioner, changes the basis of computing net income from fiscal year to calendar year, a separate return shall be made for the period between the close of the last fiscal year for which the return was made and the following December 31st. Law, page 72, line 43. H 248 — Change from Calendar Year to Fiscal Year. If the change is from calendar year to fiscal year, a sepa- rate return shall be made for the period between the close of last calendar year for which the return was made and the date designated as the close of the fiscal year. ^ 249 — Change from One Fiscal Year to Another Fiscal Year. If the change is from one fiscal year to another fiscal year, a separate return shall be made for the period between the close of the former fiscal year and the date designated as the close of the new fiscal year. T[250 — First Return on Fiscal Year Basis. If a taxpayer making his first return for income tax keeps his accounts on the basis of a fiscal year, he shall make a separate return for the period between the beginning of the calendar year in which such fiscal year ends and the end of such fiscal year. ^ 251 — Computation of Net Income (First Year). In all the above cases the net income shall be computed on the basis of such period for which separate return is made and the tax shall be paid thereon at the rate for the cal- endar year in which such period is included ; and the credits 256 INDIVIDUALS— Continued RETURNS provided in subdivisions (c) (exemptions of $1,000 and $2,000) and (d) ($200 additional for dependent person) of Section 216 shall be reduced respectively to amounts which bear the same ratio to the full credits provided in such sub- divisions as the number of months in such period bears to twelve months. H 252— Where Returns Shall Be Filed. Returns shall be made to the collector for the district in which is located the legal residence or principal place of business of the person making the return, or, if he has no legal residence or principal place of business in the United States, then to the collector at Baltimore, Maryland. Persons in the military or naval service of the United States may file their returns of income with the collector of internal revenue of the district in which they have a legal residence, or with the collector of internal revenue at Balti- more, Md. — ^Art. 26, Reg. 33, Revised. ^ 253 — By An Individual Residing in a Foreign Country. In the case of an individual having no legal residence or place of business in the United States, the return should be filed with the collector of internal revenue at Baltimore, Md. 11254 — Form of Return— What to Contain. The required return will be made on Form 1040 Revised in accordance with the instructions printed thereon, and will specifically set forth — 1. All income received from each specific source and the total thereof. 2. All the separate items of deduction claimed. 3. The amount of specific personal exemption claimed. 4. All amounts of income upon which tax has been with- held at source by withholding agent or agents on tax-free bonds. H 255 — Amended Returns. Amended returns are not required when individuals, fidu- ciaries, or withholding agents are found subject to a further tax.— I. T. Mim. 1232. 257 INDIVIDUALS—Continued RETURNS Return may be made on a basis other than that of actual receipts and disbursements. ^ 256 — Adjustment of Tax By Commissioner. As soon as practicable after the return is filed, the Com- missioner shall examine it. If it then appears that the cor- rect amount of the tax is greater or less than that shown in the return, installments shall be recomputed. If the amount already paid exceeds that which should have been paid on the basis of the installments as recomputed, the excess so paid shall be credited against the next install- ments so due, and if the amount already paid exceeds the correct amount of the tax, the excess shall be credited or re- funded to the taxpayer in accordance with the provisions of the Income Tax Law. If the amount already paid is less than that which should have been paid, the difference shall, to the extent not covered by any credits then due to the tax- payer under Section 252, be paid upon notice and demand by the collector. In such case, if the return is made in good faith and the understatement of the amount in the return is not due to any fault of the taxpayer, there shall be no penalty because of such understatement. ^ 257 — Returns Under Section 3176 of Revised Statutes. If a return is made pursuant to Section 3176, Revised Statutes, as amended, the amount of tax determined to be due under such return shall be paid upon notice and demand by the collector. Section 3176 provides that the collector is to file returns in case of failure to file, or of fraudulent re- turns. — See Law, page 169, line 17. If 258— When Tax Shall Be Paid. The tax shall be paid in four equal installments — ^the first at the time fixed by law for fihng the return, the second on the fifteenth day of the third month thereafter (June 15), the third on the fifteenth day of the sixth month thereafter (September 15), and the fourth on the fifteenth day of the ninth month thereafter (December 15). 258 INDIVIDUALS— Continued RETURNS ^ 259 — Payment Where Extension Is Granted. "Inhere an extension of time for filing a return is granted the time for payment of the first installment shall be post- poned until the date of the expiration of the period of the extension, but the time for payment of the other install- ments shall not be postponed unless the Commissioner so provides in granting the extension. In any case in which the time for the payment of any installment is at the request of the taxpayer thus postponed there shall be added as part of such installment interest thereon at the rate of one-half of 1 per cent, per month from the time it would have been due if no extension had been granted, until paid. If any installment is not paid when due, the whole amount of the tax unpaid shall become due and payable upon notice and demand by the collector. If 260 — Payment Optional. The tax may, at the option of the taxpayer, be paid in a single payment instead of in installments, in which case the total amount shall be paid on or before the time fixed by law for filing the return (March 15th) , or where an exten- sion of time for fihng the return has been granted, on or before the expiration of the period of such extension. II 261 — Beneficiary Under Trust Etate or Otherwise to Make His Own Return. Unless the beneficiary is under some disability which re- quires the fiduciary to act, the beneficiary will make his own return and account for the tax upon his entire income. — Treasury Decision 2090. If such fiduciary is legally authorized to act for such bene- ficiary as agent or attorney in fact, he may in such case, in addition to his return as fiduciary, make the personal return for the beneficiary on Form 1040, Revised. ^ 262 — Executor or Administrator to Make Return in Case of Death. In the case of the death of a person whose net income from Jan. 1 of the year in which he died was $1,000 or 259 INDIVIDUALS—Continued RETURNS $2,000 according to the marital status of the decedent. A return for such decedent must be made by the executor or administrator of the estate of the deceased, on Form 1040, Revised, and in computing the taxable income of such estate there shall be allowed the specific exemption pro- vided by law. — Treasury Decision 2090. ^ 263 — Notice of Failure to File Return to Be Served on Guardian or Agent of Non-resident Alien. When the required return has not been made by a person acting as guardian, agent of a non-resident alien, or by one acting in any other capacity in which the law makes it a duty for him to represent the individual, notice of failure to make such return will be served upon such guardian or agent. If 264 — Returns to Be Prepared by Collector in Certain Cases. If any person liable to pay an income tax for himself or others shall fail to make and deliver the return required by law, but shall consent to disclose the particulars of any business or occupation hable to pay such tax, it shall be the duty of the collector or deputy collector to make such list or return, which being distinctly read and consented to, signed and verified by oath or affirmation by the person liable to make such return, the same may be received as the Hst or return of such person. — Sec. 3173 R. S. If 264(a) — Refusal or Neglect to Make Return. If any person, corporation, company, or association fails to make and file a return or list at the time prescribed by law, or by regulations made under authority of law, or makes, wilfully or otherwise, a false or fraudulent return or list, the collector or deputy collector shall make the return or list from his own knowledge and from such in- formation as he can obtain through testimony or other- wise. In any such case the Commissioner may, from his own knowledge and from such information as he can obtain through testimony or otherwise, make a return or amend any return made by a collector or deputy collector. Any 260 INDIVIDUALS— Continued RETURNS return or list so made and subscribed by the Commissioner, or by a collector or deputy collector and approved by the Commissioner, shall be prima facie good and sufficient for all legal purposes.* ♦For method of procedure in such cases, see Section 3173 (page 167). If 265 — False Returns. There is no necessity to construe the word "false" where it is used with reference to the time in which Commissioner shall act, to mean fraudulently false. — Treasury Decision 2198. ^ 266 — Refund Portions of Amounts Paid as Penalties for Failure to File Return for the Year 1913. On March 4, 1915, Congress authorized the refundment to individuals of all amounts paid as penalties for failure to file returns for the tax-year 1913, in excess of $5. For further particulars, see Treasury Decision 2175. H 267—25 Per Cent. Penalty. Where taxpayers make application for blanks disclosing their liability in time no 25 per cent, penalty accrues, pro- vided said return is filed within 30 days after receipt of necessary blanks. T[ 26a— 50 Per Cent. Penalty. If a party liable to tax for entire year falsely states that he is liable for only portion of year, return so made is false and 50 per cent, penalty applies in full. ^ 266 — Liability of Individuals to — Specific penalties provided by the income tax are held to attach to the person and in case of death of such person are non-enforceable. Ad valorem penalties (those measured by income) attach to income and are to be enforced regardless of the death of the owner of the income by which the penalty is measured. ^ 270 — ^Waiver After Expiration of Time Limit for Assessment. Where the Hmitation of the statute as to assessment has run and a written waiver of exemption from assessment is 361 INDIVIDUALS— Continued RETURNS given by the taxpayer, the ad valorem penalties of 25 per cent, addition to tax, is not to be assessed for delinquency in filing return. If 271— Returns to Be Verified by Oath. The annual return must be verified by oath of the person making the same. Collectors are directed by law to require every return to be so verified by the person rendering it. The affidavit may be made before the collector for the dis- trict or before any officer authorized by law to administer oaths. TI 272— Oaths. (1) A return of income rendered by an individual residing abroad may be acknowledged before any duly appointed offi- cer of the country in which he resides authorized to ad- minister oaths and use an official seal. (2) If a return is executed in a State before a notary who is not required by the laws of the State to use a seal, and none is used, the notary should file with the Com- missioner of Internal Revenue the certificate of an officer possessing a seal, showing that he is duly commissioned and authorized to administer oaths; otherwise the certificate will not be recognized. (3) Returns acknowledged before commanding officers of naval vessels while at sea or in foreign ports will be accepted. (4) Returns executed before a summary court officer, United States Army, will not be accepted. — Treasury De- cision 2090. (5) May be made before Justice of Peace or any officer authorized by law to administer oaths. — Treasury Decision 2174. 11273- Persons in the naval or military service of the United States may verify their returns before any official of those services authorized to administer oaths for the purposes of those services. 262 INDIVIDUALS— Continued RETURNS Income tax returns executed abroad may be attested free of charge before United States consular officers. Where a foreign notary or other official having no seal shall act as attesting officer, the authority of such attest- ing officer should be certified to by some judicial official or other proper officer having knowledge of the appointment and official character of the attesting officer. — Art. 26, Reg. 33, Revised. Tf 274 — Extension of Time to File Return May Be Granted by Collector. When the return is not filed within the required time by reason of sickness or absence of the individual, an extension of time, not exceeding 30 days from March 15, within which to file such return may be granted by the collector, provided a written application therefor is made by the individual within the period for which such extension is desired. If 275 — Extension of Time by Commissioner. The Commissioner may grant a reasonable extension of time for filing returns wherever in his judgment good cause exists and he shall keep a record of every such exten- sion and reason therefor, except in the case of taxpayers who are abroad, no such extension shall be for more than six months. ^ 27G — Extension to Citizens of the United States, Non-resident Individuals and Corporations Abroad. An extension of time has been granted to non-resident alien individuals and corporations and American citizens re- siding abroad who because of war conditions cannot file re- turns, up to and including ninety days after the proclama- tion of the President of the United States announcing the close of the war v/ith Germany. — Treasury Decision 2581. If 277 — Returns — Five-Year Limitation. Except in the case of false or fraudulent returns, the amount of tax due under any return shall be determined and assessed by the Commissioner within five years after the return was due or was made and no suit or proceed- 263 INDIVIDUALS— Continued RETURNS ings for the collection of any tax shall be begun after the expiration of five years after the return was due or was made. 11278 — Reasonable Cause. Section 3176, Revised Statutes, as amended by Revenue Act of 1918, provides that if after delinquency has ensued, the delinquent individual or corporation shall have filed with the collector of internal revenue a return and shall accompany such return with a showing "that the failure to file it (in time) was due to a reasonable cause and not to wilful neglect, no such addition shall be made to the tax." "Reasonable cause," for the purpose of this article of the regulations, is held to be such a condition of fact as had the taxpayer in default exercised ordinary business care and prudence it would have been impracticable or impossible for him to have filed return on the prescribed time. — Art. 54, Reg. 33, Revised. If 279 — Receipts for Taxes. Every collector to whom any payment of any tax is made under the provisions of this title shall upon request give to the person making such payment a full written or printed receipt, stating the amount paid and the particular account for which such payment was made; and whenever any debtor pays taxes on account of payments made or to be made by him to separate creditors, the collector shall, if re- quested by such debtor, give a separate receipt for the tax paid on account of each creditor in such form that the debtor can conveniently produce such receipts separately to his several creditors in satisfaction of their respective de- mands up to the amounts stated in the receipts; and such receipts shall be sufficient evidence in favor of such debtor to justify him in withholding from his next payment to his creditor the amount therein stated; but the creditor may, upon giving to his debtor a full written receipt acknowledg- ing the payment to him of any sum actually paid and accept- ing the amount of tax paid as aforesaid (specifying the 264 INDIVIDUALS— Continued RETURNS same) as a further satisfaction of the debt to that amount, require the surrender to him of such collector's receipt. H 280 — Penalty and Interest. If upon review of a return by the Commissioner of In- ternal Revenue, an understatement is found to be due to negligence on the part of a taxpayer, but without intent to defraud, there shall be added as part of the tax 5 per cent, of the total amount of the deficiency plus interest at the rate of 1 per cent, per month on the amount of the deficiency of each installment from the time the installment was due. If 281 -—Payment of Taxes. An excess payment of tax in one year can be offset against an assessment of tax for a subsequent year. In the payment of income tax a fractional part of a cent shall be disregarded unless it amounts to a half-cent or more, in which case the fraction shall be increased to 1 cent. —Art. 41, Reg. 33, Revised. H 282— -Status of Income Tax. Tax due on income has the status of a debt due to the United States. Persons receiving property charged with such indebtedness must answer for the debt. — Art. 39, Reg. 33, Revised. If 283— Penalty— Failure to File Return. Any individual, corporation, or partnership required un- der this title to pay or collect any tax, to make a return or to supply information, who fails to pay or collect such tax, to make such return or to supply such information at the time or times required under the Revenue Act of 1918 shall be liable to a penalty of not more than $1,000. (This is in addition to the 25 per cent, penalty which will be assessed for failure to file return within the time required by law.) Every person having a net income of $1,000, or $2,000, according to marital status for the calendar year is required to render a return, and the penalty provided by law for refusal or neglect to file a return will be enforced regardless of the fact that the net income may be less than the exemp- 265 INDIVIDUALS— Continued RETURNS tion to which the individual is entitled. — Treasury Deci- sion 2090. fl 284 — False or Fraudulent Understatements. If the understatement is false or fraudulent and with in- tent to evade the tax, then in addition to the other penalties provided by law for false and fraudulent returns, there shall be added as part of the tax 50 per cent, of the amount of the deficiency. In these cases the amount of tax due may be de- termined at any time after the return is filed and the tax may be collected at any time after it becomes due. II 285— Penalty— Wilful Attempt to Evade Tax or File Return. Any individual, corporation, or partnership, or any officer or employe of any corporation, or member or employe of a partnership, who wilfully refuses to pay or collect such tax, to make such return or to supply such information at the time or times required under this title, or who wilfully attempts in any manner to defeat or evade the tax imposed by the Revenue Act of 1918 shall be guilty of a misdemeanor and shall be fined not more than $10,000 or imprisoned for not more than one year, or both, together with the cost of prosecution. H 286— Failure to Pay Tax. If any tax remains unpaid after the date when it is due and for ten days after notice and demand by the Collector, then, except in the case of the estates of insane, deceased or insolvent persons, there shall be added as part of the tax the sum of 5 per cent, on the amount due but unpaid plus interest at the rate of 1 per cent, per month upon such amount from the date it became due. T[ 287— Abatement of Taxes. Nothing in the law or the regulations shall be construed to release a taxable person from liability for income tax, nor shall any contract entered into after the Act of October 3, 1913 took effect be valid in regard to any Federal income tax imposed upon a person liable to such payment. 266 INDIVIDUALS— Continued RETURNS fl 288 — Income Tax Law^ — Constitutionality — Injunction to Prevent Collection. The courts have persistently refused an injunction or other extraordinary process of law to aid taxpayers in attempting to defeat collection of the tax. The question of constitutionality of the law can be considered in a suit to recover the tax, but not in a proceeding to enjoin collection ■—Treasury Decision 2142. ^28d — Taxes Illegally Assessed — Jurisdiction of Suits to Recover. Suit to recover taxes alleged to have been illegally assessed and collected may be brought directly against the United States in the U. S. District Court. — Treasury De- cision 2188. ^ 290 — Claims for Abatement of Tax. Claims for abatement of taxes erroneously assessed (Form 47), or which are excessive in amount, may, prior to collection thereof, be filed under the provisions of said Sec- tion 3220, Revised Statutes. Form 47 for Claiming Abatement may be had upon appli- cation to the collector. II 290(a)--Return Filed on Behalf of Persons Due to Sickness. If such person, owing to serious illness, is unable to make the return and application above provided for, the return and appHcation may be made by an agent, he making oath on certificate (Form 1040, Revised) that he has sufficient knowledge of the affairs and property of the non-resident alien to enable him to make a full and complete return for him or her, and that the return and application made by him are full and complete. II 290(b)— Claims for Refund Tax. When tax is collected in excess, recourse may be had only on presentation of a claim for refund (on Form 46) under the provisions of Section 3220, Revised Statutes. Section 3220, Revised Statutes, prescribes that the Com- missioner of Internal Revenue, subject to regulations pre- scribed by the Secretary of the Treasury, is authorized, on appeal to him made, to remit, refund, and pay all back taxes 267 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE erroneously or illegally assessed or collected, all penalties collected without authority, and all taxes that appear to be unjustly assessed or excessive in amount, or in any manner wrongfully collected ; also to repay to any collector or deputy collector the full amount of such sums of money as may be recovered against him in any court, etc. Tf 290(c) — Statute of Limitations Removed from Certain Claims for Refund. Claims can now be made for refund of taxes paid under the Act of August 5, 1909 (excise tax), Act of October 3, 1913 (income tax), Act of September 8, 1916 (income tax) and Act of October 3, 1917 (income tax and excess-profits tax) if the question involves a review of the return. WITHHOLDING AND PAYMENT OF TAX AT THE SOURCE. If 291 — Withholding Provisions of the Law. CITIZENS AND RESIDENT INDIVIDUALS. The withholding provisions of the law in respect to citi- zens and residents applies only to income from bonds con- taining a tax-free covenant. — See Law, page 69, line 748. 11 291 (a)— NON-RESIDENT ALIEN INDIVIDUALS The law provides that all persons, firms and corporations having control, receipt or payment of any income, of a non- resident individual (other than dividends from corporations which is taxable under the law on its net income) shall with- hold and pay the government a tax of 8% on such income, except in the case of income derived from bonds containing a tax-free covenant, when the amount of tax to be withheld and paid is 2%. — See Law, page 69, line 27-48. The Commissioner, however, may authorize the deduction and withholding of a tax on income from any securities at the rate of 8% where the owners of such income are not known. TI 291 (b)— NON-RESIDENT ALIEN CORPORATIONS. In the case of income of foreign corporations not having an office or place of business in the United States, there 268 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE shall be withheld and paid a tax of 10% (exclusive of divi- dends from corporations whose net income is taxable) ex- cept in the case of income derived from bonds or other obli- gations containing a tax-free clause, withholding will be at the rate of 2%. — See Law, page 79, line 55. Foreign corporations having an office or place of business in the United States have the status of domestic corpora- tions, and are not subject to withholding of tax at the source. Tf 292— "Debtors" or Withholding Agents. All persons, firms, etc., mentioned in the above paragraph are referred to in the regulations as "debtors" or "with- holding agents," and the word "source" is to apply to the place where the income originated and is payable. ^ 293 — Exempt Organizations Are Subject to Provisions of the Law as Withholding Agents. By a revised ruling of the Commissioner of Internal Revenue, organizations exempted by law from payment of tax are now subject to the withholding provisions of the present law. — Art. 81, Reg. 33, Revised. Also Treasury De- cision 2407. ^ 294— Individual Income from Which the Tax Is NOT to Be Withheld— Dividends. In the case of non-resident alien individuals, there shall not be withheld any tax on dividends on capital stock or from the net earnings of corporations and joint-stock com- panies or associations and insurance companies subject to like tax. ^295 — Dividends Declared and Paid by Foreign Corporations from Earnings in United States. Dividends declared by a foreign corporation which de- rives its entire income from business transacted in the United States should be treated in the same manner as dividends from domestic corporations. TI 299— * Forms and Certificates. Tax withheld from income other than bond interest will be accounted for on Income Tax Form 1042, and separate * The forms here referred to are old forms. 269 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE reports of the payments entered on Form 1042 will be made on Form 1098. Tax withheld from bond interest will be accounted for monthly on Income Tax Form 1012, and an annual summary of these will be made on Income Tax Form 1013. The annual return only will be verified. — Art. 43, Reg. 33, Revised. Ij 297 — Ownership Certificates. The owners of bonds of domestic and resident corpora- tions shall, when presenting interest coupons for payment, file a certificate of ownership for each issue of bonds, show- ing the name and address of the debtor corporation, the name and address of the owner of the bonds, whether the payee is married or the head of a family, and the amount of interest.— Art. 43, Reg. 33, Revised. See If 309 (H) to (J). ^ 298— Tax to Be Paid at the Source. The forms here referred to are old forms. Form 1000, Revised, shall be used (a) when no personal exemption is claimed against interest on bonds containing a "tax-free" covenant by citizens or residents of the United States; (b) by non-resident alien individuals, foreign cor- porations having no office or place of business in the United States, whether or not such bonds contain a "tax-free" covenant; and (c) in the case where coupons are received not accompanied by certificates of ownership. The first bank receiving coupons not accompanied by ownership cer- tificates will make a certificate crossing out "owner" and in- serting "payee" and will enter the amount of interest on line 4.— Art. 43, Reg. 33, Revised. See H 309 (H) to (J). If 299— Tax Not to Be Paid at the Source. The forms here referred to are the old froms. Form 1001, Revised, shall be used (a) when personal exemption is claimed against interest on bonds containing a "tax-free" covenant by citizens or residents of the United States, also when presenting coupons from bonds not con- taining a "tax-free" covenant; (b) by domestic partner- ships, corporations, or associations; (c) by non-resident alien partnerships ; and (d) by foreign corporations having 270 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE an office or place of business in the United States, whether or not such bonds contain a "tax-free" covenant. In case a citizen or resident individual receives interest on bonds containing a "tax-free" covenant in excess of the amount of personal exemption which the individual may- claim, any such excess must be reported on Form 1000, Re- vised.— Art. 43, Reg. 33, Revised. If 309 (H) to (J). The department will furnish blank forms of certificates to be used in connection with the collection of the income tax to such parties as may make application for the same. Private corporations and others may under certain condi- tions have these certificates printed for their own use. — Treasury Decision 1939. If 300, 301, 302, 303 Void— [Ed.] T[ 304— When Taxes Withheld Are to Be Paid. In the monthly list returns as now prescribed a space is provided to show the amount of interest paid (tax-free bonds) on which the withholding agent will be held liable for the tax. The withholding agents will not, however, forward to the collector the tax on such amounts until the filing of the annual return. If 305 — Filing Annual Returns. Withholding agents should file an annual return on Form 1013 showing amounts of tax withheld in the aggregate for each month on tax-free bonds as reported on monthly re- turns Form 1012 during the year. If 306 — Returns to Be Made to Collector of Internal Revenue. Withholding agents who are required to make monthly returns will, on or before the 20th day of each month, file with the collector for their respective districts such returns for the preceding month, accompanied by all certificates re- lating thereto; on or before the 1st day of March in each year said withholding agents shall likewise file their annual returns for the preceding calendar year. an INDIVIDUALS—Cont'd WITHHOLDING AT SOURCE If 307 — Penalty for Giving Information from Withholding Returns. The law is specific and mandatory with regard to safe- guarding from publicity the information acquired by reason of its requirements relative to annual returns of income. The law imposes the penalty of "fine, imprisonment, dis- missal from office, and discharge from employment," for making known in any manner not provided by law the amount or source of income, or any particular thereof, set forth or disclosed in any income return by any person. ^ 308 — Amended Returns. Amended returns not required when individuals or fidu- ciaries are found subject to a further tax. — See I. T. Mim. 1232. Income Derived from Interest Upon Bonds and Mortgages or Deeds of Trust or Other Similar Obligations of Corporations, etc., Containing a Tax-Free Covenant. ]f 309— Tax Withheld on Tax-Free Bonds. In any case where bonds, mortgages, or deeds of trust, or other similar obligations of a corporation contain a con- tract or provision by which the obligor agrees to pay any portion of the tax imposed by this title upon the obligee, or to reimburse the obligee for any portion of the tax, or to pay the interest without deduction for any tax which the obligor may be required or permitted to pay thereon or to retain therefrom under any law of the United States, the obligor shall deduct and withhold a tax equal to 2 per centum of the interest upon such bonds, mortgages, deeds of trust or other obligations, whether such interest is pay- able annually or at shorter or longer periods and whether payable to a non-resident alien individual or to an individual, citizen or resident of the United States or to a partnership. If309(a)« The Commissioner of Internal Revenue, however, may au- thorize such tax to be deducted and withheld in the case of interest upon any such bonds, mortgages, deeds of trust or other obligations, the owners of which are not known to the withholding agents. 27» INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE H 309(b)~ Such deduction and withholding shall not be required in the case of a citizen or resident entitled to receive such interest, if he files with the withholding agent on or before February 1, a signed notice in writing claiming the benefit of the credits provided in subdivisions (c) and (d) of Sec- tion 216 [see page 66] ; nor in the case of a non-resident alien individual if so provided for in regulations prescribed by the Commissioner under Section 217 (See page 67). Every individual, corporation, or partnership required to deduct and withhold any tax under this Section shall make return thereof on or before March 1st of each year and shall on or before June 15th pay the tax to the official of the United States Government authorized to receive it. Every such individual, corporation, or partnership is hereby made liable for such tax and is hereby idemnified against the claims and demands of any individual, corporation, or partnership for the amount of any payments made in ac- cordance with the provisions of this Section. ^ 309(c) — Tax-Free Covenant — Contract Between Issuing Corporation and Bondholder. The Government has consistently held that the so-called tax-free covenant in bonds is a contract between the issu- ing corporation and its bondholders with which the Gov- ernment has no concern. Inasmuch, however, as the great majority of the tax-free covenants in bonds are to the ef- fect that the issuing corporation "will pay coupons, etc., without deduction for any Federal income taxes which the corporation is obliged by law to retain and pay" the pro- vision limiting the amount to be retained and paid at the source to 2 % was probably designed as a measure of rehef to minimize*the obhgation of the issuing corporation to its bondholders. 11309(d)— The 2 % tax on bond interest to be withheld and paid at the source in the case of bonds containing a tax-free cove- nant is only a part of the tax assessed on interest from bonds, the bondholder being Hable for tax on such interest at the full normal and super-tax rates prescribed by law. INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE He may, however, take credit for the 2 % tax withheld in his behalf in his annual return in the manner indicated on the form of return. tf 309 (e)— Bonds Which Do Not Contain a Tax-Free Covenant. The Commissioner has ruled that under the law, a cor- poration issuing bonds without a tax-free covenant is not permitted to deduct or pay tax at the source with respect to the interest thereon; except in cases where bonds are owned by a non-resident individual or corporation not hav- ing an office or place of business in the United States. The withholding provisions of the law apply to the nor- mal income tax derived from interest payments upon bonds which do not contain a tax-free covenant clause only in cases where the bondholders are non-resident alien corporations or individuals. If interest payments are made to citizens or residents of the United States from bonds which are not tax-free, such income must be reported on Form 1001,* Revised, as there is no provision for reporting this income as subject to withholding. *0r its equivalent under any new regulations. Should a corporation desire to reimburse its bondholders in such cases, it may do so, as this is a matter wholly be- tween the parties concerned and one in which the Govern- ment is not interested. However, such income should not be reported as subject to withholding and this office will not accept tax deducted in such cases by the withholding agent. 11309(f) — Tax-Free Bonds — Important Distinction for Income Tax Purposes. Read also If 309(e). The method of reimbursing the bondholder for a specific amount of the tax on interest as- sumed by the corporation issuing bonds without a tax-free covenant or contract is a matter with which the Govern- ment has nothing to do. In these circumstances some corporations issuing bonds without such covenant but which voluntarily assume a tax of, say 2 per cent., in be- half of the bondholder, may use the simple expedient of paying coupons at 1 02 per cent, of their face value. 274 INDIVIDUALS—Cont'd WITHHOLDING AT SOURCE In order to make the proper certificates of ownership when cashing coupons and to make a proper return of in- come it is desirable that the bondholder inform himself not only whether his bond contains a tax-free covenant, but also whether the issuing corporation interprets such cove- nant as obliging it to withhold and pay the tax. If 309(g)- Here are some facts based upon official information: (1) Not all corporations issuing bonds with a so-called tax-free covenant are observing the apparent terms of such covenant. (2) Many corporations issuing bonds without a tax-free covenant are reimbursing the holder for a tax of 2 per cent, or more. (3) Some corporations issuing bonds with a tax-free covenant are assuming more than the 2 per cent, tax which by law they are required to retain and pay in behalf of the bondholder. (4) Other corporations are paying coupons without de- duction of the 2 per cent, tax only where a certificate of ownership is filed showing that the holder is not exempt from the tax. 11309(h)— USE OF CERTIFICATES OF OWNERSHIP. The regulations provide that in collecting coupons or in- terest orders the bondholder must file a proper certificate of ownership with the bank or collecting agency. See If 297. BONDS CONTAINING TAX-FREE COVENANT- EXEMPTION CLAIMED. With respect to bonds which contain a tax-free covenant and where it has been ascertained that the corporation will abide by the apparent terms of such covenant, the holder should file Form 1001 (yellow certificate) if he claims ex- emption from the tax. In this case his coupons will be paid at face value and the corporation need not withhold and pay the tax in his behalf. See H 299. 875 INDIVIDUALS— Contd WITHHOLDING AT SOURCE ff309(i)- BONDS CONTAINING TAX-FREE COVENANT- EXEMPTION NOT CLAIMED. Under the same conditions shown in the preceding para- graph, but where the holder does not claim exemption, he should file Form 1000 (white certificate). In this case a tax of 2 per cent, (read jf 309(d)) will be withheld and paid by the issuing corporation in his behalf, and he will receive the face value of his coupons. See TJ 298. !I308(j)— ALL OTHER BONDS— INCLUDING BONDS WHICH , ARE ^TAX-FREE" BUT ISSUED WITHOUT A SPECIFIC TAX-FREE COVENANT. [A "tax-free" bond under this category is a bond a cer- tain amount of tax on the interest from which has been vol- untarily assumed by the issuing corporation, but which does not contain a specific tax-free covenant or contract.] The holder of these bonds should file Form 1001 (yel- low certificate) filled out according to his taxable status under the law. His coupon will be paid at face value. See H 297 and 298. If 31 — Investment Certificates. Investment securities issued by a corporation for a term of years are corporate obligations within the meaning of the income-tax law. — Treasury Decision 2090. See H 32. If 31 1 — Promissory Note of Corporations. A simple promissory note not exceeding one year in time is not "similar to bonds, mortgages, or deeds of trust of cor- porations," but the interest on such a note when payable to a non-resident alien, is subject to withholding regardless of the amount of interest payment. ^312 — Scrip Dividend — (Amending Treasury Decision 2090). Scrip certificates issued by a corporation to its stockhold- ers in lieu of dividends, such scrip certificates bearing inter- est and redeemable at a specified time not longer than one INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE year from date of issue, are not corporate obligations similar to bonds, mortgages, or deeds of trust, and the interest pay- able thereon will be considered income. Payment in scrip is held to be equivalent to payment in cash. \l 31 3— Income from Bonds of Exempt Organizations. The owner of bonds issued by such an organization is not relieved from the filing of certificates of ownership, with coupons detached from such bonds when presenting same to a bank or other collecting agency for collection or otherwise, or to a debtor corporation or its duly designated paying agent for payment. ^ 31 4— Interest on State and Government Obligations Exempt. Income derived from the interest upon the obligations of a State ; Territory ; or any political subdivision thereof ; the District of Columbia ; securities issued under the provisions of the Federal Farm Loan Act of July 17, 1916 ; the obliga- tions of the United States or its possessions ; or bonds issued by the War Finance Corporation, is not subject to the in- come tax, and certificates of ownership in connection with coupons or registered interest orders for such interest will not be required. In the case of obHgations of the United States issued after September 1, 1917, and In the case of bonds issued by the War Finance Corporation, the interest shall be exempt only if and to the extent provided in the respective Acts authorizing the issue thereof. — Law, page 60, line 48. Tf 31 5 — Municipal District and Local Bonds — Special Assessment Districts. Special assemment districts created under the laws of the several States for public purposes, such as the improvement of streets and public highways, the provision for sewerage, gas, and light, and the reclamation, drainage, or irrigation of bodies of land, and levee and school districts, are held to be political subdivisions of a State, and income derived from interest upon the obligations of such districts shall not be included in computing net income. — Treasury Decision 1946. 277 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE The requirement of law for information at the source shall not apply to the payment of interest on obligations of the United States. — Art. 37, Reg. 33, Revised. 1[316 — Public Utility Bonds Acquired by a Municipality. Bonds of a public utility acquired by a municipality are not an obligation of the municipahty within the meaning of the law and income from such bonds is not exempt from tax. 11317— The Term "Debtor''— To Whom It Applies. The term "debtor," as hereinafter used, shall apply to all corporations, joint-stock companies or associations, and in- surance companies; and such "debtor" may appoint with- holding and paying agents to act for it in matters pertaining to the collection of this tax, upon filing with the collector of internal revenue for the district a proper notice of the appointment of such agent or agents. This notice should be placed on file in the office of the collector of internal revenue for the district in which the debtor corporation is located or has its principal place of business, and the said collector shall notify the collector of internal revenue for the district in which the duly au- thorized withholding agent is located — Treasury Decision 2135. Where such withholding agent is so authorized by the debtor corporation, he may file with the collector of his dis- trict the required returns and accompanying certificates, in which case the assessment of the tax withheld by him will be made in that district. Unless such authority is given, such reports, etc., will be furnished by the debtor corpora- tion to the collector of its district (i. e., the district in which its principal financial or business office is located), where, in such case, assessment will be made. ^ 31 8 — Non-Resident Aliens — Tax on Income from Bonds to Be Deducted and Withheld by Debtor Corporation — Certificates of Ownershop to Accompany Interest Coupons for Collection. For the purpose of collecting the tax on all coupons and registered interest originating or payable in the United 278 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE States to non-resident aliens, the source shall be the debtor (or its withholding and paying agent in the United States), who shall deduct the tax when same is to be withheld, and no other bank, trust company, banking firm, or individual taking coupons or interest orders for collection or otherwise, shall withhold the tax thereon, where coupons are accom- panied by certificates of ownership signed by the owners of the bonds upon which the interest matured. These certifi- cates shall be made on the prescribed forms and shall be made out by each owner of bonds for the coupons or interest order for each separate issue of bonds or obligations of each debtor. ^ 31 9 — Sinking Fund and Similar Bonds Retired Within an Interest Period. Where bonds, under contract provisions in the bonds, are retired within an interest period and prior to the expiration of the full term of the bond, ownership certificates will be required and should cover that part of the interest period affected between the beginning of such period and the date of the retirement of the bonds. — Treasury Decision 2090. ^ 320 — Registered Bonds — Certificates of Ownership Not Required to Accompany Interest Orders, Checks, Etc. Certificates of ownership are not required to accompany interest orders or checks in payment of interest on fully registered bonds. — Treasury Decision .2006. Also see T1329. ^ 321 — Bonds of Foreign Corporations. Bonds of foreign corporations payable as to interest wholly within the United States, or within or without the United States at the option of the owner of the bonds, to be treated, for income-tax purposes, as domestic bonds, when accompanied by certificates of ownership properly executed. In the case of items (payable in the United States) of interest upon bonds of foreign countries and interest upon bonds and dividends from stocks of foreign corporations, the fiscal agent in the United States will be the source for pur- 279 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE poses of information. If no ownership certificate is received with the item, the first bank or collection agent receiving the same shall execute a certificate, Form 1001, showing the name and address of the owner, if known, or the person presenting the item, which certificate shall be forwarded to the fiscal agent in the same manner as if the certificate had been signed by the owner. — Art 35, Reg. 33, Revised. ^ 322 — Coupon Bonds — Substitute Certificates, When Permitted. Responsible banks, bankers, and collecting agents receiv- ing coupons for collection with the aforesaid certificates of ownership attached, may present the coupons with the attached certificates to the debtor or withholding agent for collection, or such certificates may be detached and for- warded direct to the Commissioner of Internal Revenue, provided such bank, banker, or collecting agent shall sub- stitute for such certificates its own certificate, and shall keep a complete record of each transaction, showing — 1. Serial number of item received. 2. Date received. 3. Name and address of person from whom received. 4. Name of debtor corporation. 5. Class of bonds from which coupons were cut. 6. Face amount of coupons. The substitute certificates above referred to cannot be used when the owners of the bonds are non-resident aliens. In all such cases the original certificates of ownership shall be forwarded to the debtor corporation without substitu- tion. — Treasury Decision 2589; also, Art. 43, Reg. 33, Revised. For the purpose of identification, such substitute certifi- cates should be numbered consecutively, and corresponding numbers given the original certificates of ownership. — Art. 43, Reg. 33, Revised. ^ 323 — Number of Bonds Not Required. Until further notice the regulations requiring the filling in of the numbers of bonds on certificates are waived. — Treasury Decision 2022. 880 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE If 324 — Revised Certificates. Substitute certificates to be attached to interest coupons when collection agent's certificate is substitute for the cer- tificate of owner ; Exemption claimed Form 1058 Exemption not claimed Form 1059 When proper certificate is filed with the Commissioner of Internal Revenue the name of the bank or collecting agency and the fac-simile signature of person authorized to sign same may be printed or stamped on certificates 1058 and 1059.— Treasury Decision 1986. Other revised certificates will be found under proper sub- jects. TI 325 — Execution of Ownership Certificates By Banks and Trust Companies. Name may be printed or stamped and fac-simile of person authorized to sign may be used under provision specified in Treasury Decision 2258. Tf32G — Privilege of Substituting Certificates Extended to Foreign Countries. The permission here granted will extend to responsible banks, bankers, and collecting agents in foreign countries, through whom collection of such interest coupons is made. ^ 327 — Normal Tax to Be Deducted Before Payment of Interest. A debtor whose bonds may be registered, both as to principal and interest, shall deduct the normal tax of 8 per cent, from the accruing interest on all bonds (excepting bonds with a tax-free covenant), the owners of which are non-resident alien individuals, before sending out checks for said interest to registered non-resident owners or before paying such interest upon interest orders signed by the reg- istered holders of said bonds. ^ 328 — Certificates of Ownership to Specify Bonds and Amount of Interest Due. The certificates of ownership shall accompany the cou- pons, or, v/ith respect to the interest on registered bonds, 281 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE shall be filed with payer of said interest, and such certifi- cates shall describe the bonds and show the amount of cou- pons attached or the amount of interest due such owners on registered bonds and the name and address of the own- ers, and if registered in names other than the owners such names with addresses shall also be given. Certificates must be signed by the claimants, who shall use their ordinary business signatures. The certificates shall also show whether or not the claimant is single or married or the head of a family, the post-office and street address of the claimants, the internal-revenue district, and the date when signed. ^329 — Registered Bonds — Certificates of Ownership Not Required to Accompany Interest Orders — Principal and Interest. Certificates of ownership are not required to accompany interest orders or checks in payment of interest on fully registered bonds. As information to ownership of such bonds will be fur- nished by the debtor organizations, and, as no withholding occurs, where interest is paid to citizens or residents of the United States (except where the bonds are guaranteed tax- free), it will be necessary to file proper certificates with debtors for information purposes. Where proper certificates are filed, the said debtors shall stamp or write on the interest orders or checks, as the case may be, "Certificate filed with debtor," or, if the bonds are tax-free, "Exemption claimed by certificate filed with debt- or," or "Income tax withheld by debtor," if certificate is filed not claiming exemption. ^ 330 — Certificates May Be Signed by Duly Authorized Agents, Etc. Duly authorized agents may sign such certificates for the persons for whom they act, also ownership certificates may be executed for non-resident aliens by reputable foreign banks or bankers. INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE ^331 — Certificates of Corporations. Such certificate will be made on Form 1001 Revised, and must be signed in the name of the firm or organization (stating its place of business) by the president, secretary, or some other principal officer of the said corporation or organizations, or in the case of a firm or co-partnership, by a person duly authorized to sign same, and must be prop- erly dated. In the case of a foreign corporation having an oflice or place of business in the United States the certificate to be used is Form 1001 Revised. j[ 332 — Certificates of Non-Resident Aliens. Coupons, or orders for registered interest, payable in the United States, representing the interest on bonds owned by non-resident alien individuals, must be accompanied by the prescribed certificate. Form 1000 Revised. (See "Registered Bonds, H 329.) Foreign corporations having an office or place of business in the United States are exempt from the withholding pro- visions of the law and may file a certificate (Form 1001) to prevent the withholding of the tax at the source. The income of foreign corporations having no office or place of business in the United States is subject to the with- holding provisions of the law, and certificate Form 1000 should be used. This form may be executed also by responsible banks and bankers of the United States for or in behalf of non- resident alien owners of bonds of United States corpora- tions. — Treasury Decision 1988. ^ 333^ — Foreign Partnership Composed of Non-Resident Foreigners and Citizens of United States. Where a foreign partnership or firm is composed of both non-resident foreigners and citizens of the United States, or foreigners residing in the United States or its posses- sions, the certificate of ownership shall show this fact, and the name and legal address of each member of said part- nership who is a citizen of the United States, or who is a INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE foreigner residing in the United States, or its possessions, shall be given on the back of said certificate, and no part of said income shall be withheld. If 334 — Monthly List Return-— Withholding Returns Required of Corporations or Their Authorized Agents. A corporation, having bonded indebtedness, which has withheld income tax during the preceding month on tax-free bonds is required to file a monthly list return. Form 1012, showing the amount of interest paid. Certificates of owner- ship in which exemption is claimed to the extent of the amount of payment need not be listed, and if this is the only class of certificates received during the said preceding month, no return is required. However, such certificates should be forwarded to the proper collector of internal rev- enue, together with a letter of transmittal. 11335— The return should be filed with the collector of internal revenue for the district in which the debtor corporation is located or has its principal place of business, provided the said debtor corporation has not filed with the said collector of internal revenue a notice of the appointment of a duly authorized withholding agent, in which case the debtor cor- poration is not required to file a monthly list return. Form 1012, or the corresponding annual list return. Form 1013. TI33e— This notice of appointment should be placed on file in the office of the collector of internal revenue for the district in which the debtor corporation is located or has its principal place of business, and the said collector should notify the collector of internal revenue for the district in which the duly authorized withholding agent is located. The duly au- thorized withholding agent is required to file its return with the collector of internal revenue for the district in which the said withholding agent is located, and is not required to file a return with the collector for the district in which the debtor corporation is located. — Treasury Decision 2135. 284 INDIVIDUALS— Cont^d WITHHOLDING AT SOURCE H 337— Withholding agents are required to file in duplicate a monthly list return (Form 1012) giving the amount of tax withheld. Tf338— The original ownership certificates, accompanied by the monthly list returns in the case of interest on bonds of do- mestic and resident corporations, when filed with the Com- missioner of Internal Revenue shall constitute and be treated as returns of information. — Art. 35, Reg. 33, Re- vised. *| 33S — Substitute Certificates of Ownership. All substitute certificates (See If 322), of collecting agents, authorized by regulations, that are received by debtors or withholding agents will be considered the same as certificates of owners, and in entering same in making monthly list returns debtors or withholding agents will enter the name and address of the collecting agent and the number of the substitute certificate issued in lieu of the original certificate containing the name and address of the owner of the bonds. ^ 340 — Registered Bonds— Interest Orders. Responsible banks, bankers, or collecting agents receiving for collection interest orders or checks bearing endorsement "Certificate filed with debtor" may present said interest orders or checks for collection without requiring that cer- tificates of ownership be filed therewith. Registered bonds of organizations exempt from tax (If 320) may be treated in same manner as income from domestic corporation. See If 329. If 341- Where the coupons are not accompanied by certificates as heretofore prescribed, the first bank, trust company, banking firm, or individual, or collecting agency receiving the coupons for collection or otherwise, shall attach to such 285 INDIVIDUALS—Cont'd WITHHOLDING AT SOURCE coupons crossing out the word "Owner" and inserting "Payee" and will enter the amount of interest on line 4. (Form 1000 Revised.) ^ 342 — Execution of Ownership Certificates by Banks and Trust Companies. Name may be printed or stamped and fac-simile of signa- ture of person authorized to sign may be used under pro- vision specified in Treasury Decision 2258. ^ 343 — Identity of Persons Presenting Interest Coupons to Be Established. Any corporation, collecting agency, or person first re- ceiving from the owner any interest coupons * ♦ * should require the persons tendering such coupons to satis- factorily establish their identity. ^ 344 — Monthly and Annual List Returns. Withholding agents receiving coupons not accompanied by certificates of owners are required to file monthly and annual list returns in duplicate. The monthly list return will be made on Form prescribed by the Government. Monthly list returns not to be made under oath. — Treas- ury Decision 1997. An annual list return is also required to be made by such withholding agents, showing the amount of tax withheld on tax-free bonds during the preceding year on income of this character. This return must be filed on or before the 1st day of March of each calendar year. The monthly Hst returns in the form as required shall constitute a part of the annual list return to be made, and the withholding agent will not be required, in making an annual list return of the tax thus withheld, to again make an itemized list of the amount of tax withheld from each person, but will give in the annual hst return the totals of the monthly list returns for the year for which annual Ust return is made. 286 INDIVIDUALS— Cont'd WITHHOLDING AT SOURCE ^ 345 — Where Person Receiving Payment is Not Actual Owner. When the person receiving a payment falhng within the provisions of law for information at the source is not the actual owner of the income received, the name and address of the actual owner shall be furnished upon demand of the person, corporation, partnership, or association paying the income, and in default of a compliance with such demand the payee becomes liable to a penalty of not less than $20 nor more than $1,000.— Art. 36, Reg. 33, Revised. H 346 — Exempt Organizations Are Subject to Withholding Provisions of the Law. Organizations exempted by law from payment of tax (such as labor, agricultural, horticultural organizations, mutual savings banks, etc.) are subject to the provisions of the law as withholding agents when their bonds contain a tax-free clause, or if interest payments are made to non- resident aliens. ^ 347 — Tax to be Withheld by Banks on Interest Paid on Deposits Paid to Non-resident Aliens. Banks, bankers, trust companies, and other banking insti- tutions receiving deposits of money, are required to with- hold at the source the normal income tax of 8 per cent, on interest paid, or accrued, or accruing to non-resident ahens, whether on open accounts or on certificates of deposit. — Treasury Decision 2627. H 348 — Tax to Be Withheld on Payment of Interest Notes, or Notes Given for Rent. When a note shall have been given in payment of interest, rents, or other income, the maker of the note, as the "debtor" and as the "source" where the income originates, is required, in paying such note, to withhold the normal tax of 8 per cent, on the entire amount of the note, when paid to a non-resident alien. 887 INDIVIDUALS— Cont'd INFORMATION AT SOURCE ^ 349 — Purchasers of Interest Notes on Which Tax Has Not Been Withheld. If any person who has purchased or discounted any such notes omitted, in acquiring them from previous holder, to make a deduction or allowance for said tax, when the amount is paid to a non-resident alien he can look for relief only to the person from whom the notes were obtained, as the "debtor," the maker of said notes, is required to deduct, withhold, and to pay to the collector of internal revenue, the amount of the normal tax of 8 per cent, which may be due thereon. INFORMATION AT SOURCE. ^ 350 — Returns Required for Information Purposes. That all individuals, corporations, and partnerships, in whatever capacity acting, including lessees or mortgagors of real or personal property, fiduciaries, and employers, making payment to another individual, corporation, or part- nership, of interest, rent, salaries, wages, premiums, annui- ties, compensations, remunerations, emoluments, or other fixed or determinable gains, profits and income (other than payments described in Sections 254 and 255), of $1,000 or more in any taxable year, or in the case of such payments made by the United States, the officers or employes of the United States having information as to such payments and required to make returns in regard thereto by the regula- tions hereinafter provided for, shall render a true and ac- curate return to the Commissioner, under such regulations and in such form and manner as may be prescribed by him with the approval of the Secretary, setting forth the amount of such gains, profits, and income, and the name and address of the recipient of such payment. Such returns may be required, regardless of amounts (1) in the case of payments of interest upon bonds, mortgages, deeds of trust, or other similar obligations of corporations, and (2) in the case of collections of items (not payable in the United States) of interest upon the bonds of foreign countries and interest upon the bonds of and dividends from foreign corporations by individuals, corporations, or part- INDIVIDUALS— Cont^d INFORMATION AT SOURCE nerships, undertaking as a matter of business or for profit the collection of foreign payments of such interest or divi- dends by means of coupons, checks, or bills of exchange. When necessary to make effective the provisions of this Section, the name and address of the recipient of the in- come shall be furnished upon demand of the individual, cor- poration, or partnership paying the income. The provisions of this Section shall apply to the calendar year 1918 and each calendar year thereafter, but shall not apply to the payment of interest on obligations of the United States. T[ 350 (a) — Letter of Transmittal. Returns of information for the preceding calendar year shall be filed with the Commissioner of Internal Revenue on or before March 1 of each year, accompanied by a letter of transmittal, under oath (Form 1096), which will show the number of returns filed and the aggregate amount repre- sented by the payments. — Art. 34, Reg. 33, Revised. ^ 351 — Returns of Payments of Dividends. Every corporation subject to the tax imposed by this title shall, when required by the Commissioner, render a correct return duly verified under oath, of its payments of dividends, stating the name and address of each stock- holder, the number of shares owned by him, and the amount of dividends paid to him. 11352— Return of Brokers. Every individual, corporation, or partnership doing busi- ness as a broker on any exchange or board of trade or other similar place of business shall, when required by the Com- missioner, render a correct return fully verified under oath, under such rules and regulations as the Commissioner, with the approval of the Secretary, may prescribe, showing the names of customers for whom such individual, corporation, or partnership has transacted any business, with such de- tails as to the profits, losses, or other information which the Commissioner may require, as to each of such cus- 289 COLLECTION OF FOREIGN ITEMS— tomers, as will enable the Commissioner to determine whether all income tax due on profits or gains of such cus- tomers has been paid. INCOME DERIVED FROM COUPONS, CHECKS OR BILLS OF EXCHANGE ON FOREIGN BONDS, MORTGAGES, DIVIDENDS, ETC. H 353— Amounts received by citizens or residents of the United States for or in payment of interest upon bonds issued in foreign countries, and upon foreign mortgages or like obli- gations, and for any dividends upon stock or interest upon obligations of foreign corporations, associations, or insur- ance companies engaged in business in foreign countries, are subject to the income tax. — Treasury Decision 2090. Note — Dividends paid by a foreign corporation which de- rives its entire income from business transacted in the United States, to be treated in same manner as income from domestic corporations. 11 354 — Collection of Coupons, Checks, Bills of Exchange, Etc. — License to Be Obtained. All individuals, corporations, partnerships, or associ- ations, undertaking as a matter of business or for profit the collection of foreign payments of interest or dividends by means of coupons, checks, or bills of exchange shall ob- tain a license from the Commissioner of Internal Revenue, and shall be subject to such regulations enabhng the Gov- ernment to obtain the information required under this title as the Commissioner of Internal Revenue, with the approval of the Secretaiy of the Treasury, shall prescribe ; and who- ever knowingly undertakes to collect such payments as aforesaid without having obtained a license therefor, or without complying with such regulations, shall be deemed guilty of a misdemeanor, and for each offense be fined in a sum not exceeding $5,000, or imprisonied for a term not exceeding one year, or both, in the discretion of the court. Definition of foreign corporation and method of proce- dure in caes of interest on bonds of corporation. 290 COLLECTION OF FOREIGN ITEMS— Continued. ^ 355 — Application for License — ^Penalty for Failure to Obtain License. Applications for such license (Form 1017) will be made to the collector for the district in which such business is to be carried on. Upon the acceptance of such application the collector will issue to the applicant without cost a license (Form 1010) which will continue in force until revoked or canceled. Blank forms of such license, bearing the fac- simile signature of the Commissioner of Internal Revenue, will be furnished collectors on requisition, who will in all cases countersign the same before issuing it to applicant. Failure to obtain a license or to comply with regulations is punishable by a fine not exceeding $5,000 or imprisonment not exceeding one year, or both, in the discretion of the court. License not required for collection of foreign pensions paid to resident aliens or citizens of the United States. — Treasury Decision 2090. Tf 356 — License to Be Obtained for Branch Offices — Application to Be Certified to Collector. When any person, firm, or corporation shall have branch offices and desire to collect foreign interest or dividend in- come through said branch offices, the application for license or licenses shall be made by the person, firm, or corpora- tion through its principal office for its branch office or offices. Application for licenses in such cases shall be made to the collector of internal revenue for the district in which the home office is located. The names and addresses of the branch offices shall be furnished to the collector in the application of the said principal, and if the requirements of the foregoing regulations have been complied with to the satisfaction of the collector, he shall certify this fact to the collector of internal revenue for the district in which the branch office is located, and the collector to whom this cer- tification is made shall issue to such branch office a license. If the foreign item is in form of a check or bill of ex- change, the words "Information obtained and furnished by (name of collecting agent)," Also name 291 COLLECTION OF FOREIGN ITEMS— Continued. and address of licensee as the case may be, shall be endorsed or stamped thereon by such licensee ; but if the item is rep- resented by a coupon or coupons from bonds, the licensee shall attach thereto a statement identifying the same, and the endorsement or stamp showing who will pay the tax is to be placed on the statement instead of the coupon or cou- pons. Said endorsement or stamp shall be sufficient evi- dence showing that the information has been furnished. TI 357 — Statement to Be Appended to Coupons, Checks, Etc. If the size or nature of such coupons, checks, etc., makes it impracticable to make said indorsement thereon, a state- ment identifying the item on which tax is to be paid and bearing said indorsement may be attached thereto with the same effect as if the indorsement was made directly thereon.— Art. 58, Reg. 33. ^ 357 (a) — Licensee to Furnish List. Such licensee shall obtain the names and addresses of the persons from whom such items are received and shall pre- pare certificates on Form 1099 and make return on Form 1096. ^ 358 — Annual List Return. The annual list return in the form as required, together with certificates, should be forwarded to the Commissioner of Internal Revenue, Sorting Division, Washington, D. C, on or before March 1, 1919. ^ 359 — Interest on Foreign Bonds. The provisions for collection of the tax on foreign obli- gations herein set forth includes the interest upon all for- eign bonds, even though the coupons may, at the option of the holder, be payable in the United States as well as in some foreign country. If 360 — Licensee to Keep Records. All person licensed shall keep their records in such man- ner as to show from whom every such item has been re- ceived, and such records shall be open at all times to the inspection of internal-revenue officers. — Art. 62, Reg. 33. »9» PARTNERSHIPS. IT 381 — Salary Received by Foreign Employe of a Domestic Corporation for Services Abroad. Salary received by a foreign employe of a domestic cor- poration for service rendered entirely in a foreign land is not subject to deductions and withholding of the normal tax at the source. ^ 362 to Tf 367 Void.— [Ed.] PARTNERSHIPS. ^ 368— Partnership Profits. Individuals carrying on business in partnership shall be liable for income tax only in their individual capacity. There shall be included in computing the net income of each part- ner, his distributive share, whether distributed or not, of the net income of the partnership for the taxable year. If his net income for such taxable year is computed upon the basis of a period different from that upon which the net income of the partnership is computed, then his distributive share of the net income of the partnership for any account- ing period of the partnership ending within the fiscal or calendar year upon the basis of which the partner's net in- come is computed. While partnerships, as such, are not taxable, every part- nership nevertheless is required to make a return for each taxable year, stating specifically the items of its gross in- come and the deductions allowed and shall include ~in the return the names and addresses of the individuals who would be entitled to share in the net income if distributed and the amount of the distributive share of each individual. The return shall be sworn to by any one of the partners. This is done for the information of the Government. Tj 369 — Partnership Profits to Be Included in Returns Made by Individual Partners. The net annual profits of a partnership when divided and paid to the members thereof shall be included by each indi- vidual partner receiving same in his annual return of net 393 PARTNERSHIPS— Continued. income, and the tax shall be paid thereon as required by law. When the annual profits of a partnership are not dis- tributed and paid to the members thereof the respective interest of each member in said profits shall be ascertained, and the individuals entitled thereto shall include the said amount in their annual return as a part of their gross in- come, the same as if said profits had been distributed and paid to them. If a fiscal year of a partnership ends during a calendar year for which the rates of tax differ from those for the preceding calendar year, then (1) the rate for such pre- ceding calendar year shall apply to an amount of each part- ner's share of such partnership net income equal to the pro- portion which the part of such fiscal year falling within such calendar year bears to the full fiscal year and (2) the rates for the calendar year during which such fiscal year ends shall apply to the remainder. In the case of an individual member of a partnership which makes return for a fiscal year beginning in 1917 and ending in 1918, his proportionate share of any excess-profits tax imposed upon the partnership under the Revenue Act of 1917 with respect to that part of such fiscal year falling in 1917, shall, for the purpose of determining the tax im- posed by this title, be credited against that portion of the net income embraced in his personal return for the taxable year 1918 to which the rates for 1917 apply. Tf 370 — Private Bank Partnerships. Private banks (which do not have the form of corporate organizations) which transact business not in the name of the bank but in the name of individuals who compose the firm, as John Smith and Company, are held to be co-partner- ships and, as such, are required to make a return. In such cases the individuals who compose the firm, if they have income in excess of $1,000, will be required to make indi- vidual returns on Form 1040, accounting therein for their respective incomes arising and accruing from the earnings of the bank. 294 PARTNERSHIPS— Continued. 11 371 — Income — ^When Accrued. Income from a partnership accrues to the individual part- ner at the time his distributive interest is determined and reducible to possession. In returns of income made by indi- viduals for the calendar year, therefore, there should be included such income accruing from the business of partner- ships for their business years as may have been definitely ascertained by book balance, whether distributed or not. In other words, members of partnerships are required to make returns of income like other individuals for the cal- endar year and should include in their returns the net pro- ceeds of their interest in partnership profits ascertained at the end of the business year falling within the calendar or fiscal year for which the individual return is being rendered, If 372 — Life Insurance Premiums of OflScers, Employes, Etc. That premiums paid on life insurance policies covering the lives of officers, employes, or those financially interested in any trade or business conducted by the taxpayer, shall not be deducted in computing the net income of such tax- payer when the taxpayer is directly or indirectly a bene- ficiary under such policy. — Law, page 65, line 22. 1i 373 — Identity of Income. The character of partnership profits divisible between persons has no reference (except as otherwise specially pro- vided) to any character which, as income accruing to the partnership it may have borne prior to the receipt by the partnership, and hence, with the exception noted, income received from a partnership can not be traced to its source behind the partnership for the purpose of claiming indi- vidual exemption. Where the result of partnership opera- tion is a net loss, the loss will be divisible between the part- ners in the same proportion as net income would have been divisible, and may be used by the individual partners in their returns of income. — Art. 30, Reg. 33, Revised. H 374 — Limited Partnerships. For taxable status of limited partnerships under the law . see K 40. 895 PARTNERSHIPS— Continued. H 375.— Void.— [Ed.] t[37© — Net Income. The net income of the partnership shall be computed in the same manner and on the same basis as provided in Sec- tion 212, except that the deduction for contributions shall not be allowed. 11 377— Credits Allowed. The partner shall, for the purpose of the normal tax, be allowed as credits, in addition to the credits allowed to him under Section 216, his proportionate share of such amounts received as dividends and interest upon obligations of the United States and bonds issued by the War Finance Cor- poration, which are included in gross income. Tf 378.— Fiscal Year. A partnership shall have the same privilege of fixing and making returns upon the basis of its own fiscal year as is accorded to corporations, under this title. Any partnership may, at its option, designate the last day of any month as the close of its fiscal year. In each case where the partnership's fiscal year differs from the calendar year, it shall, not less than 30 days prior to March 15, give notice in writing to the collector of internal revenue of the district in which its principal place of business is located, that the day it has thus designated is the closing day of its fiscal year. Tf37d — llfdividual Partnership Profits. Undivided annual net profits of partnerships thus re- turned by the individual members thereof, and tax paid thereon, shall not, when said profits are actually distributed and paid to such members, be again included in their annual return as part of their gross income. H 380— Void.— [Ed.] FIDUCIARIES- EFFECTIVE DATE OF TREASURY DECISIONS. 11381- Treasury decisions promulgating rulings of the Internal Revenue Bureau become effective upon the date of approval unless otherwise stated therein. Cases previously adjusted in contravention of law as pronounced in such decisions, are subject to readjustment in accordance with the decision. — Art. 38, Reg. 33, Revised. FIDUCIARIES. For summary of income of estates and trusts subject to taxation see Law, page 57, line 33. II 382.— Definition of Term "Fiduciary." "Fiduciary" is a term which applies to all persons or cor- porations that occupy positions of peculiar confidence toward others, such as trustees, executors, or administrators; and a fiduciary, for income-tax purposes, is any person or cor- poration that holds in trust an estate of another person or persons. There may be a fiduciary relationship between an agent and a principal; but the word "agent" does not denote a "fiduciary" within the meaning of the income tax law. — Treasury Decision 2090. ^ 383 — Agent — Acting Under Power of Attorney. An agent acting under power of attorney and having full charge of property is not obliged to render a return as fiduciary. — Treasury Decisions 2135 and 2137; also, see II 423, 424. Tl 384. — Fiduciary Returns. Every fiduciary (except receivers appointed by authority of law in possession of part only of the property of an indi- vidual) shall make under oath a return for the individual, estate or trust for which he acts (1) if the net income of 297 FIDUCIARIES— Continued. such individual is $1,000 or over if single or if married and not living with husband or wife, or $2,000 or over if married and living with husband or wife, or (2) if the net income of such estate or trust is $1,000 or over or if any beneficiary of such estate or trust is a non-resident alien, stating specifi- cally the items of the gross income and the deductions and credits allowed by this title.. Under such regulations as the Commissioner with the approval of the Secretary may pre- scribe, a return made by one or two or more joint fiduciaries and filed in the district where such fiduciary resides shall be a sufficient compliance with the above requirement. The fiduciary shall make oath that he has sufficient knowledge of the affairs of such individual, estate or trust to enable him to make the return, and that the same is, to the best of his knowledge and belief, true and correct. 11385— Fiduciaries required to make returns under this Act shall be subject to all the provisions of this Act which apply to individuals. 11386— Fiduciaries shall, on or before March 15 of each year, make and render a return, in form prescribed by the Com- missioner of Internal Revenue (Form 1041) of the income coming into their custody or control and management from each trust estate when the annual interest of any benefi-' ciary in the income of said trust estate is $1,000 or $2,000, according to the marital status of the beneficiary. A trustee having charge of a trust estate, the net income of which is regularly distributed among the beneficiaries, is required to render a return only if any one of the benefi- ciaries is unmarried and his or her distributive interest in the net income of the trust equals or exceeds $1,000; and also, if all the beneficiaries are married and the distributive interest of any one equals or exceeds $2,000. It should be understood, however ,that the above is appli- cable only in a case where all the beneficiaries are citizens or residents of the United States. If any portion of the net income of an estate or trust is distributed to a non- 298 FIDUCIARIES— Continued. resident alien beneficiary, a return is required, and the nor- mal income tax of 8 per cent, is to be deducted and withheld from so much of the amount remitted to such beneficiaries as was not derived from dividends or from the net earnings of corporations, joint-stock companies, etc., subject to a like tax, or has been subject to the withholding of the normal tax at the source. — Primer, Question 113. ^ 387 — Non-resident Alien Beneficiary. Where a fiduciary in the United States is the recipient of trust income for which there is but one beneficiary and that beneficiary a non-resident alien, the fiduciary will be required to make full and complete return on Income Tax Form 1040 or 1040 A, as the case may be, for this trust income on behalf of the non-resident alien and pay any and all tax found by such return to be due. Where there are two or more beneficiaries, one or all of whom are non-resident aliens, the fiduciary shall render a return on Form 1041, and a personal return on Form 1040 or 1040 A for each non- resident alien beneficiary. — Art. 29, Reg. 33, Revised. If 388 — Estates and Trusts. The tax imposed by Sections 210 (normal tax on indi- vidual) and 211 additional or surtax shall apply to the in- come of estates or of any kind of property held in trust. ^ 389 — Undistributed Income of Trust Estates Subject to Both Normal and Additional Tax. Income received by estates of deceased persons during the period of administration or settlement of the estate, shall be subject to the normal and additional tax and taxed to their estates. ^ 390 — Accumulated Income for Benefit of Unborn or Unascertained Persons. Income of estates or any kind of property held in trust, including such income accumulated in trust for the benefit of unborn or unascertained persons, or persons with con- tingent interests, and income held for future distribution under the terms of the will or trust, shall be hkewise taxed. FIDUCIARIES— Continued. Tf 391 — Executors and Administrators. Where, during the period of administration, an executor converts the estate in his possession as such executor into money for the purpose of setthng the estate and closing the administration and in which conversion a profit is realized which with other income exceeds $1,000, a return of income should be made by the executor covering the period of administration in which should be included all gains, profits, and income of the estate during such period, and he should pay the tax found by such return to be due. The income of the estate being thus freed of income-tax liability may thereafter be dealt with without further regard to income- tax requirements. 11392—. Proceeds of life insurance policies payable to the estate of a decedent, when received by an executor, or adminis- trator, are, in the amount by which such proceeds exceed the premium or premiums paid by the decedent, income of the estate to be accounted for by the executor or adminis- trator. This return is to be made on Income Tax Form 1040 or 1040 A.— Art. 29, Reg. 33, Revised. ^ 393— Two Estates. A fiduciary acting for a beneficiary in more than one estate or trust is required to account for each estate sepa- rately when the amounts are such as to require the filing of a return, and also a return of information. — Art. 29, Reg. 33, Revised. 11394— A fiduciary acting for a minor or insane person having a net income of $1,000 or $2,000, according to the marital status of such person, will be required to file a return for such incompetent on Form 1040 and 1040 A and pay the tax found by such return to be due. — Art. 29, Reg. 33, Revised. If 395— Stock dividends paid from earnings or profits accumulated after March 1, 1913, received by a fiduciary and retained as 800 FIDUCIARIES— Continued. an accretion to the estate under the terms of the will or trust are held to be income to the estate and taxable as such to the estate. — Art. 29, Reg. 33, Revised. usee— Income held for future distribution under the terms of the will or trust shall be likewise taxed except when re- turned by the beneficiary for the purpose of the tax. — Art. 29, Reg. 33, Revised. 11397- The beneficiary will be required in the case of trust estates to account for the actual amounts distributed or credited to him. — Art. 29, Reg. 33, Revised. If 398— Trust, Return of. Where, in the case of more than one trust, the creator of the trust in each instance is the same person and the trustee in each instance is the same, the trustee should make a single return on Form 1041 for all of the trusts in his hands, notwithstanding the fact that they arise from different instruments. When a trustee holds trusts created by different persons for the benefit of the same beneficiary, he should make return for each trust separately on Form 1041. This ruling is based on the identity of the creator and the identity of the trustee of the various trusts, and not upon the identity of the beneficiary. — Art. 29, Reg. 33, Revised. If 399 — Tax to Be Assessed to Fiduciary Direct — When. The tax, in each instance, except when the income is re- turned by the beneficiary, is to be assessed to the executor, administrator, or trustee, as the case may be. If 400— When Tax Is Not Paid by Fiduciary. Where the income is to be distributed to the beneficiaries periodically, whether or not at regular intervals, the tax shall not be paid by the fiduciary, but there shall be included in computing net income of each beneficiary his distributive share, whether distributed or not, of the net income of the 301 FIDUCIARIES— Continued. estate or trust for the taxable year, or if his net income for the taxable year is computed upon a basis different from that upon the basis of which the net income of the estate or trust is computed, then his distributive share of the net income of the estate or trust for the last annual accounting period of such estate or trust prior to the close of the fiscal or calendar year upon the basis of which such beneficiary's net income is computed. In such cases the beneficiary shall, for the purpose of the normal tax, be allowed as credits, in addition to the credits allowed to him under Section 216, his proportionate share of dividends and interest received upon obligations of the United States, any State or political subdivision thereof as are received by the estate or trust. 11401 — In the following cases the tax shall be imposed upon the net income of the estate or trust and shall be paid by the fiduciary. In such cases the estate or trust shall, for the purpose of normal tax, be allowed the same credits as are allowed to single persons under Section 216. (See Law, page 65, line 30.) (1) Income received by estate of de- ceased persons during the period of administration or set- tlement of the estate; (2) Income accumulated in trust for the benefit of unborn or unascertained persons, or persons with contingent interests; (3) Income held for future dis- tribution under the terms of the will or trust. Notice of failure to file a return as required shall be served upon the fiduciary. If 402 — Depreciation — Deduction in Return of. In the case of a trust estate where the terms of the will or trust or the decree of a court of competent jurisdiction provides for keeping the corpus of the estate intact, and where physical property forming a part of the corpus of such estate has suffered depreciation through its employ- ment in business, a deduction from gross income for the pur- pose of caring for this depreciation, where the deduction is applied or held by the fiduciary for making good such de- preciation, may be claimed by the fiduciary in his return of 802 FIDUCIARIES— Continued. income. Fiduciaries should set forth in connection with their returns the provision of law, trust, or decree requiring such depreciation deduction where any exists or when actual depreciation occurs, the amount thereof, and that the same has been or will be preserved and applied as such. All amounts paid by fiduciaries to beneficiaries of trust estates from the income of such trust estates, whether from re- serves or otherwise, are held to be distributions of income and will be treated for income-tax purposes in accordance with the provisions of law and regulations applicable to in- come of such beneficiaries. — Art. 29, Reg. 33, Revised. ]l 403 — Returns of Joint Fiduciaries. A return made by one of two joint fiduciaries filed in the district where such fiduciary resides, shall be a sufficient compliance with the requirements of the law. If 404 — Withholding by Fiduciaries. Any part of the annual income of trust estates not dis- tributed becomes an entity, and as such, is liable for the normal and additional tax, which must be paid by the fidu- ciary. When the beneficiary is not in esse and the income of the estate is retained by the fiduciary, such income will be taxable to the estate as for an individual and the fidu- ciary will pay the tax, both normal and additional. * * * When the gross net income not distributed and remaining in the hands of a fiduciary is less than $5,000, the estate will be listed as a beneficiary and only the normal income tax will be assessable, and such tax will be paid by the fidu- ciary. When the gross net income not distributed and re- maining in the hands of a fiduciary exceeds $5,000 such income is subject to both the normal and additional tax, and the estate will be listed as a beneficiary and both the normal and additional tax will be paid by the fiduciary. ]| 405---Trust Estates As Entities. Where income is accounted for in a return of income by the executor, administrator, or trustee, as the case may be and the tax shall have been assessed and paid under such 303 FIDUCIARIES— Continued. return, such income is thereby freed of all tax liability and may be thereafter dealt with without further regard to the provisions of the income tax law. 11400— Under the provisions of the Law it is held that estates during the period of administration have but one benefi- ciary, and that beneficiary is the estate. Therefore, a return on Form 1040 or 1040 A, subject to all the deductions and exemption, shall be made by the executor or administrator for such beneficiary and the entire tax paid thereon. — Art. 29, Reg. 33, Revised. If 407 — Fiduciaries Acting for Incompetents. In all cases where fiduciaries act for incompetents they are held, for the purpose of the income tax, to be acting as the agents of such incompetents and must pay all tax (normal and additional) chargeable on such income in their hands as though the persons for whom they act were acting for themselves. ^ 408 — Fiduciaries Indemnified for Taxes Paid in Behalf of Beneficiary. Trustees, executors, administrators and other fiduciaries are indemnified against the claims and demands of every beneficiary for all payments of taxes which they shall be required to make under the provisions of the law; and they shall have credit for the amount of such payments against the beneficiary or principal in any accounting they make as such trustees or other fiduciaries. ]\ 409 — Return to Include Only Income Accruing From Trust, Unless Otherwise Authorized by Beneficiary. As each such fiduciary acts solely in behalf of the bene- ficiaries of the trust, the annual return required in such cases has reference only to the income accruing and pay- able through said fiduciary, and not to the income of the beneficiary derived from other sources. If, however, such fiduciary is legally authorized to act for such beneficiary as 804 FIDUCIARIES— Continued. agent or attorney in fact, he may in such case also make for the beneficiary the personal annual return (Form 1040, Re- vised) required by law.- If 41 — Expenses of Administration of Estates Not Deductible. Expenses of administration of an estate, such as court costs, attorney's fees, executors' commissions, etc., are chargeable against the corpus of the* estate and are not allowable deductions in a return of a fiduciary on Form 1041.— Treasury Decision 2090. ^411 — Administrator or Executor. Administrators or executors may, immediately after their discharge, upon final accounting, file with the proper col- lector of internal revenue a return of income for the income of the estate for the calendar year in which the administra- tion was closed, and should pay the tax found by such return to be due immediately upon receipt of notice and demand for the amount of such tax. There should be attached to this return a' copy of the certificate, under seal, setting forth the fact of final accounting and discharge of the execu- tor or administrator. The liability for return is fixed by the law as of December 31, and return will be required in accordance with the provisions of law existing on that date. 11412— An ancillary administrator is held to be merely an agent of the domici|i^ry administrator and should transmit to him all information as to income of the estate received by the ancillary administrator, to the end that the original admin- istrator may make a return covering the entire income of the estate.— Art. 26, Reg. 33, Revised. 11413— Deed of Trust. A deed of trust must be absolute so far as the conveyance of title is concerned and irrevocable by the donor, other- wise the income from the property in question will accrue to the donor and must be accounted for by him. — Art. 29, Reg. 33, Revised. 305 FIDUCIARIES— Continued. ^414 — Fiduciary Depreciation. Depreciation not allowed fiduciaries as a deduction from gross income in cases where no depreciation reserve is maintained, but the amount claimed as a deduction is paid to the beneficiary as income. — Treasury Decision 2267. Ti 41 5 — Inspection of Executor's Return — Beneficiary Not Entitled To. • An executor acts for his principal and not for the benefi- ciaries of the estate of his principal. Beneficiaries are not entitled, as such, to an inspection of returns of income filed by such executor. — Art. 26, Reg. 33, Revised. ^ 41 6 — Annual Return to Include List of Beneficiaries, Showing Amount Paid to Each. The annual return of the fiduciary shall contain a hst of the name and full address of each beneficiary and the share of said income to which each may be entitled. There must also be entered opposite the name of each beneficiary the amount of exemption, if any, claimed by him, the amount of income on which the beneficiary is liable for tax, and the said return shall be signed and sworn to by the fiduciary, if an individual, making same, and his full address must be stated. If the fiduciary is an organization, the return shall be signed and sworn to by the president, secretary, or treasurer of said organization. If 41 7 — Personal Exemption Allowed to Each Ward or Cestui Trust. Guardians or trustees are allowed to make a personal exemption of $1,000, or if married, $2,000, from the net income received from all sources of each ward or cestui trust. H 41 8 — No Penalty for Delay in Payment of Tax from Estates of Insane, Deceased or Insolvent Persons. When a personal return from such estates or persons has been rendered, delay in payment of taxes assessed against such persons or estates is not penalized. 306 FIDUCIARIES— Continued. ^ 41 9 — Income of a Beneficiary-r-Liability to Tax. A beneficiary is liable for the normal tax upon the amount of net income derived by him from a taxable source through a fiduciary, less the amount of exemption claimed, and is also liable for the additional tax assessable on the amount of net income received by him in excess of $5,000 ; and in order to determine whether the net income of a beneficiary is or is not in excess of $5,000 and subject to the additional tax, the amount derived by him from an estate and all other taxable sources is required to be shown on his personal annual return. ^420 — Personal Representative to Make Return of Individual in Case of Death. If the net income of a decedent from January 1 of the year in which he died to the date of his death was $1,000 or over, a return for such decedent must be made by his personal representative on Form 1040, Revised, and such representative may claim all deductions and exemption to which the decedent would have been entitled under the law. Ti 421 — Administrator or Executor. Liability for payment of income tax attaches to the per- son of an executor or administrator for income tax up to and including the date of his discharge, regardless of the fact that the time in which claim is made and filed against the estate has expired or where, prior to distribution and discharge, the executor or administrator had notice of his obligations to the Federal Government or where he failed to exercise due diligence in determining whether or not such obligations existed. 11422— Liability for the tax due from a deceased person, or from his estate, also attaches to the estate itself, and when by reason of distribution of the estate and discharge of the executor or administrator it shall appear that collection of the tax can not be made from the executor or administrator, the collector will make demand on the distributees for their proportionate share of the tax due and unpaid. — Art. 29, Reg. 33, Revised. 307 FIDUCIARIES— Continued. If 423— Agents. Agents not acting in a fiduciary capacity have no respon- sibility with reference to making return of income turned over to resident aliens or citizens of the United States. — Treasury Decision 2090. For responsibility of the agent or representative of non- resident aliens, see If 472. Tf424 — Power of Attorney — Fiduciary Relation Cannot Be Created By. A fiduciary relationship for the purposes of the income tax can not be created by a power of attorney. An agent having entire charge of property with authority to effect and execute leases with tenants entirely on his own respon- sibility and without consulting his principal, paying taxes and expenses and all other charges in connection with the property out of funds in his hands from collection of rents, merely turning over the net profits from the property periodically to his principal by virtue of authority conferred upon him by a power of attorney, is not a fiduciary within the meaning of the income tax law. In all cases where no legal trust has been created in the estate controlled by the agent and attorney the liability under the law rests with the principal. — Art. 29, Reg. 33, Revised. U 425 — Guardians, Trustees, Executors, Etc., as Fiduciary Agents, to File Returns. Guardians, trustees, executors, administrators, agents, receivers, conservators, and all persons, corporations, or associations acting in any fiduciary capacity, hereinafter referred to as fiduciary agents, who hold in trust an estate of another person or persons, shall file returns. ^ 42e—Certificates. Certificates are required to be filed for information pur- poses. See index, "Reporting at the Source." T[ 427 — Form 1015 — Exemption Claimed. Certificate Form 1015, Revised, may be filed when exemp- tion is claimed. 303 FIDUCIARIES— Continued. ^ 428 — Form 1019-— When Exemption is Not Claimed. When such exemption is not claimed, notice thereof on Form 1019, Revised, should be filed with the withholding agent. Form 1019, Revised, however, cannot be used when the income affected is payable by the fiduciary to a bene- ficiary who would not be liable under the statute for incom-e tax, if such income were payable to such beneficiary directly. — Treasury Decision 2231. When the fiduciary uses Form 1019, Revised, the debtor organization becomes the source for the deduction and withholding of the normal tax in the case of tax-free bonds. fl 429 — Certificates to Be Filed for Each Issue of Bonds and for Each Trust— Certificates 1015 and 1019 May Be Adapted. Fiduciaries are required to file Forms 1015, Revised, or 1019, Revised, according to the nature of the claim to be made by the fiduciary, for each issue of bonds and for each trust. Therefore, where fiduciaries have custody and control of more than one estate or trust, and said estates or trusts have as assets bonds of corporations of the same issue, the said fiduciaries may adapt Forms 1015 and 1019, Revised, by changing the words "estate or trust" in lines 1, 2 and 3 of said forms to the plural, and writing on the blank line provided for (name of estate or trust) the words; "As noted on the back hereof." In such cases the notation on the back of the certificate should show for each estate or trust: (a) The name of the estate or trust. (b) The amount of bonds. (c) The amount of the interest. In all other respects the certificates should be filled out as indicated thereon. — Treasury Decision 1987. 11430 — Non-resident Alien Fiduciaries — Certificates of Ownership to Be Used With Coupons Detached from Bonds of Domestic Corporations. Form 1000, Revised, is provided to be attached to coupons from bonds or other obligations of domestic corporations 309 FIDUCIARIES— Continued. owned by non-resident alien individuals, organizations and fiduciaries, for the purpose of declaring ownership of bonds of domestic corporations, etc., and to be attached to interest coupons detached from said bonds when presenting same for payment. If 431 — Returns of Fiduciaries Paying $1,000 or More. All persons, corporations, partnerships, associations and insurance companies, in whatever capacity acting, including lessees or mortgagors of real or personal property, trustees acting in any trust capacity, executors, administrators, re- ceivers, conservators and employers, making payment to an- other person, corporation, partnership, association, or insur- ance company, of interest, rent, salaries, wages, premiums, annuities, compensation, remuneration, emoluments, or other fixed or determinable gains, profits and income (other than payments described in Sections 254 and 255) of $1,000 or more in any taxable year, or, in the case of such payments made by the United States, the officers or employes of the United States having information as to such payments and required to make returns in regard thereto by the regula- tions hereinafter provided for, are hereby authorized and required to render a true and accurate return to the Com- missioner of Internal Revenue, under such rules and regula- tions and in such form and manner as may be prescribed by him, with the approval of the Secretary of the Treasury, setting forth the amount of such gains, profits and income, and the name and address of the recipient of such payment : Provided, That such returns shall be required, regardless of amounts, in the case of payments of interest upon bonds and mortgages or deeds of trust or other similar obligations of corporations, joint-stock companies, associations and in- surance companies, and in the case of collections of items (not payable in the United States) of interest upon the bonds of foreign countries and interest from the bonds and dividends from the stock of foreign corporations by persons, corporations, partnerships, or associations, undertaking as a matter of business or for profit the collection of foreign payments of such interest or dividends by means of coupons, checks, or bills of exchange. 310 NON-RESIDENT ALIENS— When necessary to make effective the provisions of this Section the name and address of the recipient of income shall be furnished upon demand of the person, corporation, partnership, association, or insurance company paying the income. The provisions of this Section shall apply to the calendar year nineteen hundred and seventeen and each calendar year thereafter, but shall not apply to the payment of in- terest on obligations of the United States. NON-RESIDENT ALIENS. H 432— Definition. Non-resident aliens have been defined as citizens or sub- jects, firms, corporations or organizations of a foreign coun- try who are not a resident of the United States. — ^Treasury Decision 1977. ^ 433 — Aliens Temporarily Residing in United States. Aliens who are physically present in the United States but only temporarily resident or employed therein (as for a season or other similarly definite term, and with the expec- tation or intention of leaving the United States upon the termination of employment or accomplishment of the pur- pose which necessitated presence in the United States) are within the class of "Persons residing elsewhere." — ^Treasury Decision 2242. ^ 434 — American Wife of Non-resident Alien. An American woman who marries a foreigner takes the nationahty of her husband. — Treasury Decision 2090. Tl 435 — Resident Aliens. For purposes of the income tax it is held that where for business purposes or otherwise an alien is permanently lo- cated in the United States, has there his principal business establishment and is there permanently occupied or em- ployed, even though his domicile may be without the United States, he will be held to be within the definition of "Every person residing in the United States, but not a citizen thereof." — Treasury Decision 2242. 811 NON-RESIDENT ALIENS—Continued. 11 436 — Method of Establishing Residence in United States. Aliens coming to the United States with the intention of becoming residents thereof within the meaning and intent of the income tax statute, may establish that fact and have the privilege of resident aliens under the statute by filing with withholding agents a certificate (Form 1078) under oath, and which certificate shall be filed by said withholding agents with Collectors of Internal Revenue as justification for withholding on the basis of "residence in the United States." — Treasury Decision 2242. II 437 — Income Subject to Tax. Subject to the deductions allowed, and set forth below, the income of non-resident aliens subject to the normal and ad- ditional tax consists of only the gross income from sources within the United States, including interest on bonds, notes and other interest-bearing obligations of residents, cor- porate or otherwise, dividends from resident corporations, and including all amounts received (although paid under a contract for the sale of goods or otherwise) representing profits on the manufacture and disposition of goods within the United States. 1l 438 — Non-resident Alien Individuals. A non-resident alien individual shall make a full and ac- curate return of all net income received from sources within the United States, regardless of amount, unless the tax on such income has been fully paid at the source ; and is not en- titled to the benefit of the several deductions and credits provided, unless such return is filed by him or his authorized agent. — Art. 32, Reg. 33, Revised. If 43d — Non-resident Aliens. — Services Rendered by, in a Foreign Country. Compensation paid for services rendered in a foreign coun- try, including per diem allowance for business and travel ex- pense, not taxable. — Treasury Decision 2152. ^ 440 — Royalties Paid to Non-resident Aliens Royalties paid to non-resident aliens are held to be income accruing by reason of property owned or business carried on within the United States. — Treasury Decision 2137. 312 NON-RESIDENT ALIENS— Continued. ^441— .Sale of Stock. When a non-resident alien who owns stock in an American corporation disposed of same by sale, the sale and dehvery being made within the United States, the profit will be held to have been derived from sources within the United States and is to be included for the purposes of income tax. — Art. 4, Reg. 33, Revised. 51 442 — Income from Dividends. In making return of income from dividends on capital stock or from the net earnings of corporations, etc., non- resident aliens shall not include such income derived from sources without the United States. ^443. — Individual Income From Dividends Subject to Additional Tax Only. In the case of non-resident alien individuals the amount received on the stock or from the net earnings of domestic corporations which are taxable on their net income are sub- ject to the additional tax only. Income from dividends should be included in every return, but for purposes of the normal tax only, the amount of such income may be deducted as a credit. ]j 444 — Income From Dividends Accruing to Foreign Corporations. Foreign corporations not engaged in business within the United States and not having any office or place of business therein, are not subject to the tax on dividends received from the net earnings of domestic corporations. NOTE. — Record owners of stock under the Provisions of the Revenue Act of 1916, as amended, were required to disclose, by ownership certificate (Form 1087) the name and address of the actual owner of stock in order to determine tax liability, and if the record owner did not exercise his right to disclose actual ownership, the tax was withheld by the debtor corporation. Under the Revenue Act of 1918, provision is made that dividends paid by domestic corporations to non-resident alien individuals are not subject to the normal tax, but are 313 NON-RESIDENT ALIENS— Continued. subject to additional tax, and that dividends paid by domes- tic corporations to foreign corporations, not having a place of business in the United States are not taxable. As there will be no withholding in connection with divi- dends paid under the Revenue Act of 1918, it is not known whether the procedure of filing ownership certificates by record owners will be required disclosing the names of the actual owners. ![445 — Record Owner Liable for Tax. (See ^444 above.) Dividends on stock of domestic corporations or resident alien corporations are held, prima facie, to be income to the record owner of the stock, and such record owner will be liable for income tax, normal or additional, according to his or its individual or corporate status, unless a disclosure of actual ownership is made to the Commissioner of Internal Revenue which will show who the owner is and his address, and that the record owner is not the actual owner. (Form 1087 is provided for this purpose.) j[ 446 — Record Owner to Make Return and Pay Tax. (See T[ 444 above.) In all cases where the actual owner is a non-resident alien individual and the record owner is an individual, firm or cor- poration in the United States, citizen or resident alien, or a non-resident alien, and the aforesaid showing of actual own- ership is made, the record owner will be held, for income tax purposes, to have receipt, custody, control and disposal of the dividend income, and will be required to make return for the actual owner and pay the additional tax found by such return to be due. ^447 — Certificate to Disclose Actual Ownership of Stock. (See II 444 above.) A certificate has been provided for disclosing actual own- ership (Form 1087, Revised) for the use of the foreign (actual) owner — whether an individual, firm or organiza- tion — to be filed with his, her or its representative in the United States. This certificate is to be filed with the record owner by the non-resident alien person, firm or corporation for whom the record owner acts. 314 NON-RESIDENT ALIENS— Continued. A certificate once filed disclosing the actual owner will be held to answer for all the requirements under this regulation until ownership shall change, when it will be necessary to disclose the actual owner as in the first instance. When a return is not required to be filed by or on behalf of the actual owner, the showing may be made upon the certification of the record owner. — Art. 32, Reg. 33, Revised. Upon the showing thus made, either by certification or return, as the circumstances may require, the Commisisoner of Internal Revenue will make such assessments and issue such instructions to debtors and withholding agents as will insure the proper collection of tax in accordance with the respective tax liabilities. — Art. 32, Reg. 33, Revised. ^ 448 — Returns of Dividends When Actual Owner is a Non-resident Individual. When the actual owner is a non-resident alien individual, a return (Form 1040) shall be made. When the net amount exceeds $5,000 said custodian shall pay the additional tax on such income. If 449 — ^When Actual Owner is a Non-resident Corporation. Where the actual owner is a non-resident alien corpora- tion, return (Form 1031 or 1030 for insurance companies) will be made regardless of amount of the dividend paid. ^ 450 — When Actual Owner is a Non-resident Alien Partnership. When it shall appear from the disclosure provided for that the actual owner is a non-resident ahen partnership, all certificates making such disclosure shall be transmitted to the collector for information of the Commissioner of In- ternal Revenue. ^ 451 — Proceduce When Stockholder of Record is Other Than the Non-resident Alien Individual Actual Owner, and is a Non-resident Alien. Dutch Administration offices being non-resident alien cor- porations not engaged in business or trade in the United States, and not having an office or place of business therein, 315 NON-RESIDENT ALIENS— Continued. and such Dutch Administration offices being the registered owners of stock of domestic or other resident corporations in theUnited States, are prima facie liable for the normal income tax on income derived from dividends on capital stock or from the net earnings of the aforesaid domestic or other resident corporations in the United States and to hav- ing the tax deducted and withheld from such income. It ap- pearing that such Dutch Administration offices, while reg- istered owners of stock, are not the actual owners thereof, but that they have issued their bearer certificates, with coupons attached, against said stock, and that dividends on said stock are collected for the account of the holders of said bearer certificates, and that the relation sustained by said Dutch Administration offices to the said bearer-certificate holders is that of agent. For the purpose of administration, the Dutch Administration offices may appoint an agent in the United States and give notice of that fact by filing, in duplicate, with each corporation issuing the stock so held by said Dutch Administration offices. — Treasury Decision 2386. Tf 452 — When Record Owner is Non-resident Alien Corporation. For the purpose of claiming exemption from withholding at the source on domestic dividend payments, non-resident alien corporations who are record owners are authorized the use of certificate (Form 1087), to disclose actual ownership of stock. The certificate should be modified by striking out the words "to be filed with representative in the United States of such Foreign Principal" in the caption and the words "in the United States" in the body of the form. — Treasury Decision 2452. II 45a-Void— [Ed.] % 454 — Deductions Allowed. A non-resident alien individual shall receive the benefit of the deductions and credits provided for in this section only by filing or causing to be filed with the Collector of Internal Revenue a true and accurate return of his total income, re- ^ 316 NON-RESIDENT ALIENS— Continued. ceived from all sources, corporate or otherwise, in the United States, in the manner prescribed by this title, including therein all the information which the Commissioner may deem necessary for the calculation of such deductions and credits; and in case of his failure to file such return, the collector shall collect the tax on such income, and all prop- erty belonging to such non-resident alien individual shall be Hable to distraint for the tax. — Law, page 66, line 8. ^ 455 — AUowable Deductions Specified. In computing the net income of a non-resident alien there shall be allowed as deductions — T[ 456— EXPENSES. All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other com- pensation for personal service actually rendered and includ- ing rentals or other payments required to be made as a con- dition to the continued use or possession, for purposes of trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equky. ^ 457— INTEREST. The proportion of all interest paid within the taxable year by such person which the amount of his gross income from sources within the United States bears to the amount of his gross income from all sources within and without the United States. H 458— TAXES. Taxes paid or accrued within the taxable year imposed by the authority of the United States (except income, war-profits and excess-profits taxes), or by the authority of any of its possessions, or by the authority of any State or territory, or any county, school district, municipality, or other taxing subdivision of any State or territory, not in- cluding those assessed against local benefits. 317 NON-RESIDENT ALIENS— Continued. 1|45d— LOSSES. Losses sustained during the taxable year, and not com- pensated for by insurance or otherwise, if incurred in trade or business. Losses sustained during the taxable year and not com- pensated for by insurance or otherwise, if incurred in any transaction entered into for profit though not connected with the trade or business to the extent of transactions entered into within the United States. Losses sustained during the taxable year of property within the United States, not connected with the trade or business, if arising from fires, storms, shipwreck, or other casualty, or from theft, and if not compensated for by insur- ance or otherwise. ^ 460— BAD DEBTS. Debts ascertained to be worthless and charged off within the taxable year. fl 461— SUMMARY OF DEDUCTIBLE LOSSES. The summary of deductible losses allowed citizen and res- ident individuals (Pars. 163 to 183) will furnish further de- tails as to losses allowed as a deduction to non-resident aliens. Tl 462 — Depreciation. A reasonable allowance for the exhaustion, wear and tear, and obsolescence of property within the United States arising out of its use or employment in the business or trade. 11463- ■ :ii In the case of buildings, machinery, equipment, or other facihties, constructed, erected, installed, or acquired, on or after April 6, 1917, for the production of articles con- tributing to the prosecution of the present war, and in the case of vessels constructed or acquired oft or after such date for the transportation of articles or men contributing to the prosecution of the present war, there shall be allowed a reasonable deduction for the amortization of such part of 318 NON-RESIDENT ALIENS— Continued. the cost of such facihties or vessels as has been borne by the taxpayer, but not again including any amount otherwise allowed under this title or previous Acts of Congress as a deduction in computing net income. At any time within three years after the termination of the present war the Commissioner may, and at the request of the taxpayer shall, re-examine the return, and if he then finds as a result of an appraisal or from other evidence that the deduction originally allowed was incorrect, the taxes imposed by this title and by Title III for the year or years affected shall be redetermined; and the amount of tax due upon such re- determination, if any, shall be paid upon notice and demand by the collector, or the amount of tax overpaid, if any, shall be credited or refunded to the taxpayer in accordance with the provisions of section 252. ^ 464 — Mines, Oil and Gas Wells, Other Natural Deposits and Timber. In the case of mines, oil and gas wells, other natural de- posits, and timber, a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar conditions in each case, based upon cost including cost of development not otherwise deducted, is an allowable deduc- tion from gross income. In the case of such properties ac- quired prior to March 1, 1913, the fair market value of the property (or the taxpayer's interest therein) on that date shall be taken in lieu of cost up to that date. In the case of mines, oil and gas wells, discovered by the taxpayer, on or after March 1, 1913, and not acquired as the result of purchase of a proven tract or lease, where the fair market value of the property is materially disproportionate to the cost, the depletion allowance shall be based upon the fair market value of the property at the date of the discovery, or within 30 days thereafter. Such reasonable allowance in all the above cases to be made under rules and regulations to be prescribed by the Commissioner with the approval of the Secretary. In the case of leases the deductions provided by this paragraph shall be equitably apportioned between the lessor and lessee. 819 NON-RESIDENT ALIENS—Continued. ^ 465-— Deductions for Improvements. Deduction shall not be allowed for any amount paid out for improvements made to increase the value of any property or estate. T[ 466 — Contributions, Gifts, Etc. Contributions or gifts made within the taxable year to corporations organized and operated exclusively for re- ligious, charitable, scientific, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any pri- vate stockholder or individual, or to the special fund for vocational rehabilitation authorized by Section 7 of the Vo- cational Rehabilitation Act, to an amount not in excess of 15 per centum of the taxpayer's net income as computed without the benefit of this paragraph. Such contributions or gifts shall be allowable as deductions only if verified under rules and regulations prescribed by the Commissioner, with the approval of the Secretary. This deduction shall be allowed only as to contributions or gifts made to domestic corporations, or to such vocational rehabilitation fund. 1[ 467 — Deductions by Non-resident Aliens. The deductions for Expenses, Losses incurred in trade or business, Debts, Depreciation, Amortization of cost of spe- cial property. Depreciation and Depletion of Mines, etc., and Losses of previous years, as set out in paragraphs 463, 404, respectively, shall be allowed non-residents aliens only if and to the extent that they are converted with income arising from sources within the United States. The proper appor- tionment and allocation of such deductions with respect to sources of income within and without the United States shall be determined under rules and regulations prescribed by the Commissioner of Internal Revenue. The benefit of all deductions and credits may be had only if the non-resident alien files, or causes to be filed, with the collector, and in the manner prescribed by the Commis- sioner, a true and accurate return of his total income re- ceived from all sources within the United States. However, the benefit of the credits provided in t[ 453, in the discretion 320 NON-RESIDENT ALIENS— Continued. of the Commissioner and except as otherwise provided, may be received by filing a claim therefor with the withholding agent. 11468— At the time of fihng return for the taxable year 1918 a taxpayer may file a claim in abatement based on the fact that he has sustained a substantial loss (whether or not actually realized by sale or other disposition) resulting from any material reduction (not due to temporary fluctuation) of the value of the inventory for such taxable year, or from the actual payment after the close of such taxable year of rebates in pursuance of contracts entered into during such year upon sales made during such year. In such case pay- ment of the amount of the tax covered by such claim shall not be required until the claim is decided, but the taxpayer shall accompany his claim with a bond in double the amount of the tax covered by the claim, with sureties satisfactory to the Commissioner, conditioned for the payment of any part of such tax found to be due, with interest. If any part of such claim is disallowed then the remainder of the tax due shall on notice and demand by the collector be paid by the taxpayer with interest at the rate of 1 per centum per month from the time the tax would have been due had no such claim been filed. If it is shown to the satisfaction of the Commissioner that such substantial loss has been sus- tained, then in computing the tax imposed by this title the amount of such loss shall be deducted from the net income. ^469 — If no such claim is filed, but it is shown to the satis- faction of the Commissioner that during the taxable year 1919 the taxpayer has sustained a substantial loss of the character above described then the amount of such loss shall be deducted from the net income for the taxable year 1918 and the tax imposed by this title for such year shall be re- determined accordingly. Any amount found to be due to the taxpayer upon the basis of such redetermination shall be credited or refunded to the taxpayer in accordance with the provisions of Section 252. 331 a NON-RESIDENT ALIENS— Continued. fl 470— -Credits Allowed. For the purpose of the normal tax only there shall be allowed the following credits: (a) The amount received as dividends from a corporation which is taxable under this title upon its net income, and amounts received as dividends from a personal service cor- poration out of earnings or profits upon which income tax has been imposed by Act of Congress ; (b) The amount received as interest from obligations of the United States, and bonds issued by the War Finance Corporation, which is included in gross income; (c) In the case of a single person, the personal exemption of $1,000, or in the case of the head of a family or a mar- ried person living with husband or wife, a personal exemp- tion of $2,000. A husband and wife living together shall receive but one personal exemption of $2,000 against their aggregate net income, and in case they make separate re- turns, the personal exemption of $2,000 may be taken by either, or divided between them ; (d) $200 for each person (other than husband or wife) dependent upon and receiving his chief support from the taxpayer, if such dependent person is under eighteen years of age or is incapable of self-support because mentally or physically defective. 11471- . The marital credit and the credit for dependents as pro- vided in subdivisions (c) and (d) of Section 216 shall be allowed to non-resident alien only if such country, which imposes an income tax, of which he is a citizen or subject, allows a similar credit to citizens of the United States not residing in such country. See paragraph 454 for further conditions under which non-resident aliens shall have benefit of deductions and credits. TJ 472 — Returns — Agents or Representatives of Non- resident Aliens to Make Returns and Pay Tax The responsible heads, agents, or representatives of said non-resident aliens who are in charge of the property owned NON-RESIDENT ALIENS— Continued. or business carried on within the United States by non- resident aliens shall make fuUand complete return of the income therefrom on Form 1040, Revised, and shall pay any and all tax, normal and additional, assessed upon the said income of non-resident aliens, except where the income tax on income so in their receipt, custody or control, shall have been withheld at the source. — Treasury Decisions 2109 and 2313. 11473- The liabihty, under the provisions of the law, to render personal returns, on or before March 15 next succeeding the tax year, of annual net income accrued to them from sources within the United States during the preceding calendar year, attaches to non-resident aliens as in the case of returns required from citizens and resident ahens. Therefore, a return on Form 1040, Revised, is required except in cases where the total tax liability has been or is to be satisfied at the source by withholding or has been or is to be satisfied by personal return on Form 1040, Revised, rendered in their behalf. Returns should be rendered to the collector of in- ternal revenue for the district in which a non-resident alien carries on his principal business within the United States or, in the absence of a principal business within the United States and in all cases of doubt, to the collector of internal revenue at Baltimore, Maryland, in whose district Washington is situated. — Treasury Decision 2313. 11474- Where non-resident aliens have various sources of income within the United States so that at any one source or from all sources combined, the amount of income shall call for the assessment of additional tax and a return of income shall not be filed by or on behalf of a non-resident alien for the purpose of the assessment of income tax, the Commissioner of Internal Revenue will cause a return of income to be made and include therein the income of the non-resident alien from all sources concerning which he has information and shall assess the tax and collect the same from one or more 323 NON-RESIDENT ALIENS— Continued. or all of the sources of income within the United States of said non-resident alien, without allowance for deductions and credits. — Art. 32, Reg. 33, Revised. ^ 475 — Exempt Income. Non-resident aliens will not be required to make return of any of the classes of income specified as exempt and received by them from sources in the United States. — Art. 32, Reg. 33, Revised. ^ 476 — Fiduciaries. A fiduciary acting in the capacity of trustee, executor, or administrator, when there is only one beneficiary and that beneficiary a non-resident alien, shall render a return on Form 1040, Revised ; but when there are two or more bene- ficiaries, one or all of whom are non-resident aliens, the fidu- ciary shall render a return on Form 1041, Revised, and a personal return on Form 1040, Revised, for each non-resi- dent alien beneficiary. Tf 477 — Non-resident Alien — Agent for. Agent for non-resident alien, whether an individual or corporation, stands in place of the principal and should exe- cute Form 1040, Revised, for principal, when principal is liable to tax on income passing through agent's hands. — Treasury Decision 2135. II 478 — Withholding at Source of Income. The person, firm, corporation, etc., in the United States, citizen or resident alien, in whatever capacity acting, hav- ing control, receipt, disposal or payment, etc., of fixed or de- terminable annual or periodic gains accruing to a non- resident alien individual from sources within the United States, including income from corporate obligations (other than dividends of domestic corporations) , shall deduct a tax equal to 8 per cent, thereof, with the exception of tax-free bonds which shall be at the rate of 2 per cent. TI479- When all income tax to which income of a non-resident alien is subject is not withheld at the source, a return of income will be required to be filed by or on behalf of said 324 NON-RESIDENT ALIENS— Continued. non-resident alien, and penalty for failure to make return in time will attach. All property in the United States of a non-resident alien will be subject to distraint for collection of tax and penalty. 11 480 — Salary, Rents, Etc. It is held that salaries, wages, commissions, and rents paid by domestic corporations, resident individuals, or part- nerships to non-resident alien employes for services ren- dered entirely in a foreign country and for property located in a foreign country are not subject to deduction and with- holding of the normal tax, and such payments of income win not be subject to the income tax in the hands of the recipient as from a source within the United States. — Art. 32, Reg. 33, Revised. Tf 481 — Return By Agent. The agent of a non-resident alien is responsible for a cor- rect return of all income accruing to his principal within the purview of the agency, and the agent will be held re- sponsible for a complete return of all such income. The agency appointment will determine how completely the agent is substituted for the principal for income-tax pur- poses. — Art. 32, Reg. 33, Revised. ]] 482 — Income of Foreign Corporations Having No OiTice or Place of Business in United States Subject to Withholding. All provisions of the law relating to withholding the nor- mal tax from the income of non-resident alien individuals from sources within the United States, apply also to the income of corporations not engaged in business in the United States and not having any office or place of business therein. 11483— The withholding provisions of the law relating to such corporations apply — 335 NON-RESIDENT ALIENS— Continued. 11484- To income derived from bonds, etc., of domestic or other resident corporations, regardless of amount. Tax to be withheld 8 per cent., except on tax-free bonds a tax of 2 per cent shall be withheld. 11485- The normal tax on the character of income specified and payable to non-resident firms, corporations, etc., will be de- ducted, withheld and paid to the proper officer of the United States Government authorized to receive it, unless the firm, corporation, etc., entitled to the payment shall file a certifi- cate (Form 1086) , under penalty of false claim, as provided, and only those firms, corporations, etc., which have "an office or place of business" in the United States can use such certificate. The corporations which are permitted to use such certificate are required to make and render a return of income to the Collector of Internal Revenue for the district in which they have their office or place of business. — Treas- ury Decision 2374. ^486 — Foreign Firms, Corporations, Etc., Which Are Exempt from Withholding of Their Income. To enable debtor corporations to distinguish between foreign firms, corporations, etc., which have, and those which have not "any office or place of business within the United States," a certificate (Form 1086) has been provided for the use of such firms, organizations, etc., as "have an office or place of business in the United States" to claim exemption from having their income withheld at the source. ^ 487— Refund, On Return. Where, upon filing return of income, it appears that a non-resident alien is not liable for income tax, but neverthe- less, income tax shall have been withheld at the source, in order to obtain a refund on the basis of the showing made by the return there shall be attached to the return a state- ment showing accurately the amounts of tax withheld, with the names and post office addresses of all withholding agents. — Art. 32, Reg. 33, Revised. 326 CORPORATIONS, ETC. RELATING TO THE INCOME TAX IMPOSED BY SECTION 230 OF THE REVENUE ACT OF 1918, ON CORPORATIONS, JOINT-STOCK COMPANIES, ASSOCIATIONS, AND INSURANCE COMPANIES. 11488— In lieu of the taxes imposed by Section 10 of the Revenue Act of 1916, as amended by the Revenue Act of 1917 ; and by Section 4 of the Revenue Act of 1917, the Revenue Act of 1918 imposes upon the net income of every corporation, joint-stock company, association, and insurance company for the calendar year 1918, a tax of 12 per cent, of the amount of such income in excess of the credits provided under Section 236. See Law, page 79, line 29. f[ 48d— Term "Taxable Year." The term "taxable year" or "taxable period" means the calendar year or the fiscal year ending during such calendar year upon the basis of which the net income is computed. j[ 490— Term "Corporation." The term "corporation" includes joint-stock companies, associations, and insurance companies. 11491 — ^Joint-Stock Companies and Associations Denied. The term "joint-stock companies" or "associations" shall include associations, common-law trusts, or organizations by whatever name known which carry on or do business in an organized capacity, whether created under and pursuant to State laws, trust agreements, declarations of trust, or other- wise, the net income of which, if any, is distributed or dis- tributable among the members or shareholders on the basis of the capital stock which each holds or, where there is no capital stock, on the basis of the proportionate share or cap- ital which each has, or has invested, in the business or property of the organization, all of which joint-stock com- panies or associations shall in their organized capacity be 327 CORPORATIONS— Continued. DEFINITIONS subject to the tax imposed by this Act, and shall make re- turns of annual net income accordingly. — Art. 58, Reg. 33, Revised. Tf 492 — Philippine and Porto Rican Corporations. In Porto Rico and the Philippine Islands the income tax shall be levied, assessed, collected and paid in accordance with the provisions of the Revenue Act of 1916, as amended by the Revenue Act of 1917; Provided: That the Porto Rican or Philippine Legislature shall have power by due enactment to amend, alter, modify, or repeal the income tax laws in force in Porto Rico or the Philippine Islands, re- spectively. For the purpose of credits and deductions under the Revenue Act of 1918, taxes imposed in Porto Rico or the Philippine Islands shall not be considered as having been levied under the provisions of said Act. See H 777. If 493 — Incomplete Corporations. Corporations which have applied for but have never re- ceived charters and corporations which have received char- ters but have never perfected their organizations and which as entities have transacted no business and had no income from any source may, upon presentation of the facts to the collector, be relieved from the necessity of making returns, so long as they remain in this unorganized condition. In the absence of a showing to this effect to the collector of in- ternal revenue, such companies will be required to make re- turns and will be liable to the penalties of the law for fail- ure to do so. — Art. 60, Reg. 33 Revised. 1[ 494^ — Corporations Dissolved. A corporation which was dissolved in 1918, prior to passage of the Revenue Act of 1918, is subject to tax. (Brady et al. v. Anderson, 240 Fed., 665). A corpora- tion so situated will make a return on Revised Form 1031, covering the period in 1918 during which it was in business prior to its dissolution. If it shall have previously made a return covering this period and shall have paid any excess profits tax under the Revenue Act of 1917, it shall be CORPORATIONS— Continued. DEFINITIONS entitled to credit for the amount of such tax so paid against any excess-profits tax assessable against it under the Revenue Act of 1918. Dissolved corporations whose fiscal year coincides with the calendar year will make returns covering the period from January 1 to the date of dissolution, and corporations having a fiscal year other than the calendar year will make returns covering the period from the beginning of the fiscal year to the date of dissolution. — Treasury Decision 2090. ^ 495 — Limited Partnerships. Limited partnerships — that is, partnerships having one or more special partners who may share in the profits of the firm but whose liability for the debts of the company is lim- ited to the amount of capital invested by such special part- ner or partners — are held to be associations within the meaning of this title, and as such are required to make re- turns of annual net income and pay any tax thereby shown to be due. The income received by the members out of the earnings of such limited partnerships will be treated in their personal returns in the same manner as if it were dividends on the stock of corporations and will be subject to the additional or surtaxes in the hands of the recipient. — ^Art. 62, Reg. 33 Revised. II 496 — Common-law Partnerships. Common-law partnerships are not associations within the meaning of the income tax law, and are not taxable as such. They must, however, make returns. 11 497 — Private Banks — Associations. Private banks which have the form of corporate organi- zations, elect officers and a board of managers, have a dis- tinctive name, a fixed situs, and distribute their net earnings upon the basis of the amount of capital invested by the members or owners, are held to be associations within the meaning of the Federal income tax law, and in their organ- ized capacity should make returns of annual net income and pay any income tax thereby shown to be due. 329 CORPORATIONS— Continued. DEFINITIONS 11498 — The holders of the stock or the owners of the bank will be exempt from the normal tax to the extent of the divi- dends or earnings which they receive from such private banks as make returns in their organized capacity and pay income tax in accordance therewith. The individual owners of the bank will not be required to return as income for the purpose of the normal tax any dividends or earnings re- ceived from the private bank which pays the tax on its net earnings, but for the purpose of the surtax the divi- dends will be returned as income by the individual stock- holders or owners. — Treasury Decision 2137. If 499 — Private Banks as Associations — Assessments Against. It is not purposed to assess tax against such banking as- sociations and then, also, against the individual members of such associations. — Treasury Decision 2152. K 500 — Private Banks — Individual Ownership. When it can be clearly shown that a private bank is owned by one man, it is evident that such bank is not an association within the meaning of the Federal income tax law, and that therefore such bank will not be required to make a return such as corporations and associations are required to make, but the individual owner, if he has a net income of $1,000 or more, will be required to make a return on Form 1040, showing in such return the income which he receives not only from the bank but from all other sources. — Treasury Decision 2137. fl 501 — Corporations Required to Make Returns — Mutual Telephone and Mutual Insurance Companies Not Exempt. Every corporation not specifically enumerated as exempt shall make the return of annual net income required by law whether or not it may have any income liable to tax, or whether or not it shall be subordinate to or controlled by another corporation. — See H 711, "Consolidated Returns." 330 CORPORATIONS— Continued. DEFINITIONS |[ 502 — Liability of Close Corporation. A corporation formed as a family affair to hold property together and not to sacrifice in selling does not come within the class of corporations specifically enumerated as exempt from the requirements of the Federal income tax law, and is required to make a return of annual net income showing therein all income arising and accruing to it from all sources and to pay any income tax shown by such returns to be due. — Treasury Decision 2137. Tf 503 — Income of Contracting Companies. The Department requires no special system of bookkeep- ing, neither does it require any specific method by which the net income to be returned by corporations shall be deter- mined. In the case of a large contracting company, which has numerous uncompleted contracts which probably, in some cases, run for periods of several years, there does not ap- pear to be any objection to such corporations preparing its return in such manner that its gross income will be arrived at on the basis of completed work — that is to say, on jobs which have been finally completed and payments made dur- ing the year in which the return is made. If the gross in- come is arrived at in this method, the deductions from gross income should be limited to the expenditures made on ac- count of such completed contracts. Tf 504 — Domestic Corporation Doing Foreign Business. A domestic corporation doing the greater part of its busi- ness in the United States and having its principal place of business in this country and transacting business in Porto Rico through a branch office, is required to report in its re- turn of annual net income its entire earnings from all sources, including those arising and accruing to the branch in Porto Rico or elsewhere. The return of such corporation will be made to the col- lector of internal revenue of the district in this country in which is located its principal place of business. — ^Treasury Decision 2137. 331 CORPORATIONS— Continued. DEFINITIONS jf SOS — Returns of Holding Companies. In a case wherein a holding company actually takes up each month on its books its proportionate share of the earn- ings of the underlying companies, such holding company will be required to include in its gross income the amounts thus taken up regardless of the fact that the same may not have been actually paid to it in cash. The fact that the underlying companies credit to the holding company the amount of earnings to which it is entitled on the basis of the stock it holds, together with the fact that the holding company takes up on its books the amount thus credited, renders it incumbent upon the holding company to return these amounts as income, regardless of the fact that the underlying companies needed these earnings and used them in making extensions and improvements and in furtherance of their business. Expenditures for such extensions and improvements being chargeable to the property account of the subsidiary com- panies are not deductible from the gross income and will therefore not have the effect to reduce the earnings to their respective shares of which the stockholders are entitled. — Treasury Decision 2137; also see tf 711, "Consolidated Returns." 11 SOB — Subsidiary Companies Required to Make Returns. Parent and subsidiary companies are distinct entities and each must make detailed returns and each is required to pay the tax. Net earnings of subsidiary companies turned over to parent company are dividends within meaning of the law. — Treasury Decision 2137; also see H 711, "Consolidated Returns." ^ SOT — Place of Filing Returns by Domestic Corporations Having Principal Place of Business in Foreign Country. In the case of domestic corporations whose books of ac- count and other data are kept in foreign countries, the re- turns should be made to the collector of internal revenue of the district in which they have branch offices in this coun- try, if they have such branch offices. Otherwise, the returns 332 CORPORATIONS— Continued. DEFINITIONS of annual net income of such corporations should be made to the collector of the district in which are located the statu- tory offices of the corporations. — Treasury Decision 2137. ^ 508 — Tentative Returns. In cases wherein foreign corporations or domestic cor- porations doing business in foreign countries are unable to assemble their data in time to make their returns of annual net income within the prescribed time, it will be permissible for such corporations upon a showing of this fact to file with the collector of internal revenue a tentative return in which there shall be approximated, as nearly as possible, the actual business tranacted during the year. This tentative return will be substituted by a true and accurate return as soon as the necessary data to make such true and accurate return shall be available. ^ 509— Collectors of internal revenue are authorized to grant an extension of time not in excess of 30 days from the date when returns are due, such extension to be granted only in cases wherein the neglect to file the return within the pre- scribed time was due to the sickness or absence of an officer whose signature to the return was necessary. Foreign cor- porations or domestic corporations doing business in for- eign countries cannot be granted an extension of tim.e merely for the reason that they are unable to assemble their data to make the return within the prescribed time. In all such cases, liabiHty to the penalty of the Act can be obviated only by filing a tentative return as hereinbefore indicated. — Treasury Decision 2137. 11510— The Revenue Act of 1918 provides that the Commissioner of Internal Revenue may grant an extension of time for the filing of returns when in his judgment good reason ex- ists therefor. 1[ 51 1 —Return Period. The return for a completed period must be made inde- pendently of any other period. A corporation changing 333 CORPORATIONS— Continued. DEFINITIONS from the basis of a calendar year to a fiscal year, and be- cause of said change having a part of the calendar year for which return is to be made, will be required to make a sep- arate return for the fraction of the calendar year, and an- other separate return for the entire fiscal year; as June 30 being designated as the end of the fiscal year, the part of the calendar year from January 1 to June 30 must be covered in a return to be made on or before March 1 then following, and on or before 60 days next following June 30 (next after the filing of return for the fractional part of a cal- endar year) a return must be made and returned for the en- tire fiscal year of the corporation. — Treasury Decision 2029. ^BIS^-Rent. Payments measured by a fixed percentage on the stock of a railroad corporation whose lines are leased by another railroad corporation and which rent is payable by the lessee directly to the stockholders of the lessor corporation, have, under the income tax law with respect to the corporation paying such sums, the status of a rental payment. In such cases there are two corporations involved, the lessor and the lessee — one the rent payer and the other the rent receiver. To the lessee rental payments are an expense of operation ; to the lessor the rentals are an income. A contract which provides that the rentals shall be paid to a third party, not a party to the contract, does not change the character of the payment, nor relieve the lessor from liability to tax on the rental income which the lessee pays to it or to such third party. The income of the third party, the stockholder, is dividends on the stock which he holds in the lessor company. Dividends cannot be paid unless the lessor has an income out of which to pay them. Hence the lessor company is required under the law to return as income the rentals which the lessee is required to pay. In paying direct to the stockholders the lessee is acting as the agent of the lessor, and the amounts received by stockholders are, in effect and in fact, dividends received out of the earnings of the lessor. — Treasury Decision 2090. 331 CORPORATIONS— Continued. DEFINITIONS If 51 3 — Leased Properties. When a corporation shall have leased its property in con- sideration that the lessee shall pay in lieu of rental an amount equivalent to a certain rate of dividend on its capi- tal stock or the interest on its outstanding indebtedness, to- gether with taxes, insurance, or other fixed charges, such payments shall be considered rental payments and shall be returned by the lessor corporation as income, notwithstand- ing the fact that the dividends and interest are paid by the lessee direct to the stockholders and bondholders of the lessor. The lessee, in making these payments direct to the bondholders and the stockholders, does so as the agent of the lessor, and the latter is none the less liable to return the amounts thus paid as income and to pay any tax that may be due thereon. — Treasury Decision 2620; also Art. 102, Reg. 33, Revised. The fact that a corporation has conveyed or let its prop- erty and has thus parted with its management and control or has ceased to engage in the business for which it was originally organized will not relieve it from liability to in- come tax. If it has or may have income directly or indirectly from any source, it must make a return, account for all such income, and pay any tax assessable upon such income. — Art. 102, Reg. 33, Revised. ^ 51 4 — Interest Deduction by Corporations Operating Leased or Purchased Lines. A railroad company operating leased or purchased lines shall include all receipts derived therefrom, and, if bonded indebtedness of such lines has been assumed, such operating company may deduct the interest paid thereon to be com- puted as indicated in 1| 610 and 679. If 51 5 — Lessee Corporations Not to Include Capital Stock or Indebtedness of Lessor Corporations. Corporations operating leased lines should not include the capital stock of the lessor corporations in their own state- ment of capital stock outstanding at the close of the year. The indebtedness of such lessor corporations should not be included in the statement of the indebtedness of the lessee 335 CORPORATIONS— Continued. DEFINITIONS unless the lessee has assumed the same. Each leased or sub- sidiary company will make its own separate return, ac- counting for therein all income which it may have received by way of dividends, rentals, interest, or from any other source. — See H 711, "Consolidated Returns." Tf 51 — Foreign Corporations Having Branch Offices in United States to Designate Principal Office. A foreign corporation having several branch offices in the United States should designate one of such branches as its principal office and should also designate the proper officers to make the required return. II 51 7 — Fiscal Year Returns of New Corporations. In the case of new corporations, if they shall file or shall have filed within the prescribed time, a notice designating the last day of some month as the close of the fiscal year, such corporations will be permitted to make their returns as of the period ended with the date designated, provided the period intervening between the date of organization of the corporation and the date designated as the close of its fiscal year does not exceed 12 months. If such period does exceed 12 months, the corporation will make a return for the portion of the calendar year preceding the beginning of the fiscal year, which return must be filed on or before the 15th day of March next following the calendar year of which it is a part. Corporations partially organized during the year 1918 should file a return for the period ended December 31, 1918, unless they shall have established a fiscal year for this purpose, and if they shall have actually done no business during the period for which the return is made, that fact will be set out in a notation on or a rider attached to the return. TI 51 8 — Change of Name of Corporation. The mere change in name does not constitute a new cor- poration. If the business was continuous throughout the year, no change in ma^nagement or operation other than the change of name, the return should be made covering the business transacted throughout the year, such return to be 336 CORPORATIONS— Continued. EXEMPT made by the corporation in the name which it bears at the end of the year, with a notation on the return to the effect that the name had been changed, giving both the old and new names. If, however, a distinct new corporation was organized to take over the property of the old, both corpora- tions will be required to make separate returns covering the periods of the year during which they were respectively in charge of the business. All corporations having an existence as such during all or any portion of a year, unless coming within the classes spe- cifically enumerated as exempt, are required to make re- turns. New corporations will make returns for the period from the date of their organization to December 31. The net income in all such cases will be ascertained in the man- ner provided in Section 232 of the Revenue Act of 1918 and the specific credit shall be reduced to an amount which bears the same ratio to the full credit as the number of months in the period bears to twelve months. ^f 51 9 — Corporations Organized During the Year to Make Returns. A corporation organized and transacting no business within the calendar year of its organization must, neverthe- less, make and file a return on the basis of the calendar year unless such corporation shall designate a fiscal year other than the calendar year in the manner and form as provided for that purpose. The duty to make a return de- pends upon corporate or associational existence and not upon the receipt of income. — ^Treasury Decision 2090. EXEMPT CORPORATIONS. Tf 520 — Corporations Exempt from Tax — Conditional. Corporations or associations organized and operated ex- clusively for religious, charitable, scientific, or educational purposes, business leagues, chambers of commerce, boards of trade, civic leagues, cemetery companies, and pleasure and recreation clubs, are not, as such, exempt from the require- ments of this title. Their exemption is conditional, and in 337 CORPORATIONS— Continued. EXEMPT order to be relieved from liability under the law they must file with the collector of internal revenue an affidavit set- ting out the character and purpose of the organizations, and showing that no part of any income which they receive inures to the benefit of any private stockholder or individ- ual, and that such income is used exclusively for the pro- motion of the purposes for which organized as indicated in the particular paragraphs under which exemption is claimed. — Art. 67, Reg. 33, Revised. ^521 — Corporations — ^When Not Exempt. A corporation is not exempt simply and only because it is primarily not organized and operated for profit. If income within the meaning of the law arises and accrues to a cor- poration which is not organized for profit, such income will be subject to tax. — Treasury Decision 2137 ; also see U 528. U 522 Corporations Exempt from Tax — Unconditional. The Act specifically enumerates and exempts from its pro- visions the income of the following corporations, associa- tions, etc.: 1. Labor, agricultural, or horticultural organizations ; 2. Mutual savings banks not having a capital stock repre- sented by shares ; 3. Fraternal beneficiary societies, orders or associations (a) operating under the lodge system or for the exclusive benefit of the members of a fraternity itself operating under the lodge system, and (b) providing for the payment of life, sick, accident, or other benefits to the members of such society, order or association or their dependents. — See U — ; 4. Domestic building and loan associations ; and co-opera- tive banks without capital stock organized and operated for mutual purposes and without profit ; 5. Cemetery companies owned and operated exclusively for the benefit fo their members ; 6. Corporations organized and operated exclusively for religious, charitable, scientific, or educational purposes or for the prevention of cruelty to children or animals, no part of the net income of which inures to the benefit of any private stockholder or individual ; CORPORATIONS— Continued. EXEMPT 7. Business leagues, chambers of commerce, or boards of trade, not organized for profit and no part of the net income of which inures to the benefit of any private stockholder or individual ; 8. Civic leagues or organizations not organized for profit, but operated exclusively for the promotion of social welfare ; 9. Clubs organized and operated exclusively for pleasure, recreation, and other non-profitable purposes, no part of the net earnings of which inures to the benefit of any privato stockholder or member; 10. Farmers' or other mutual hail, cyclone, or fire in- surance company ; Mutual ditch or irrigation companies; Mutual or co-operative telephone companies; or like organizations of a purely local character, the in- come of which consists solely of assessments, dues, and fees collected from members for the sole purpose of meeting expenses ; 11. Farmers', fruit growers', or like associations, or co- operative societies, organized and operated as sales agents for the purpose of marketing the products of members and turning back to them the proceeds of sales, less the neces- sary selling expense, on the basis of the quantity of produce furnished by them ; 12. Corporations organized for the exclusive purpose of holding title to property, collecting income therefrom, and turning over the entire amount thereof, less expenses, to an organization which itself is exempt from the tax imposed by this title; 13. Federal land banks and national farm-loan associa- tions as provided in Section 26 of the Act approved July 17, 1916, entitled "An Act to provide capital for agricultural development, to create standard forms of investment based upon farm mortgage, to equalize rates of interest upon farm loans, to furnish a market for United States bonds, to create Government depositaries and financial agents for the United States, and for other purposes;" or 14. Personal service corporations. 339 CORPORATIONS— Continued. EXEMPT ^523 — Labor, Agricultural and Horticultural Organizations. Agricultural or horticultural organizations, which are ex- empt under this title, do not include those corporations engaged in growing agricultural or horticultural products, raising live stock or similar products for profit, but will in- clude only those organizations which, having no net income inuring to the benefit of their members, are educational or instructive in character, and which have for their purpose the betterment of the conditions of those engaged in these pursuits, the improvement of the grade of their products, and the encouragement and promotion of those industries to a higher degree of efficiency. — ^Treasury Decision 2090 ; also Art. 73, Reg. 33, Revised. Included in this class as exempt are those organizations such as county fairs and like associations of a quasi-public character, which, through a system of awards, prizes, or pre- miums, are designed to encourage the production of better live stock, better agricultural and horticultural products, and whose income, derived from gate receipts, entry fees, dona- tions, etc., is used exclusively to meet the necessary ex- penses of upkeep and operation. — Art. 73, Reg. 33, Revised. Societies or associations which have for their purpose the holding of annual or periodical race meets, and from which profits inure or may inure to the benefit of the members or stockholders do not come within the terms of this exemp- tion. — Art. 73, Reg. 33, Revised. 11524- Corporations engaged in agricultural or horticultural pur- suits for plantations and disposing of the products thereof are held to be operating for profit and are not entitled to exemption as agricultural organizations. — Treasury Decis- ion 2090. If 525 — Agricultural Organizations. Corporations owning sugar or other plantations and dis- posing of the products thereof are held to be operating for profit and are not entitled to exemption as agricultural or- ganizations. — Treasury Decision 2090. 340 CORPORATIONS— Continued. EXEMPT ^ 528— Societies Not Agricultural or Horticultural. A corporation engaged in the business of raising stock or poultry, or growing grain, fruits, or other products of this character, as a means of livelihood and for the purpose of gain, is an agricultural or horticultural society only in the sense that its name indicates the kind of business in which it is engaged and, as such, is not exempt from the requirements of the law, and must make returns and pay any income tax thereby shown to be due. — Treasury Decision 2090 ; also Art. 74, Reg. 33, Revised. U 527 — Domestic Building and Loan Associations. A domestic building and loan association entitled to ex- emption is one organized under and pursuant to the laws of the United States or under and pursuant to the laws of some State or Territory thereof, and which is actually carrying on for the benefit of its members a building and loan association business in accordance with the laws under which it is organized. The fact that such an association issues fully paid or prepaid shares, calling for a specified rate of interest or dividends, will not disqualify it for ex- emption. The exemption is without qualification other than that the association is a domestic building and loan asso- ciation. If a corporation by any other name is carrying on an exclusive building-and-loan business, before it is entitled to exemption it will be incumbent upon it to show to the satisfaction of the Commissioner of Internal Revenue that it is in fact a building and loan association. — Art. 70, Reg. 33, Revised. ^ 528 — Qualifications for Exemption. In every instance wherein exemption is conditioned upon the ground that no part of the net income received by cor- porations inures to the benefit of any private stockholder or individual, it will be necessary, before such organizations will be classed as exempt, for them to show to the satisfac- tion of the collector or the Commissioner of Internal Revenue (1) The character and purpose of the organization; (2) The source from which all its income is derived ; (3) What disposition is made of such incomes; and 341 CORPORATIONS— Continued. EXEMPT (4) Whether or not any of it is credited to surplus or inures or may inure to the benefit of any private stockholder or individual. — Art. 78, Reg. 33, Revised. ^ 529 — Organizations, Exemption Doubtful. Any corporation which entertains any doubt as to its status under the law, for the reason that it does not clearly come within one or another of the classes of those specifical- ly enumerated as exempt, should, within the prescribed time, file a return and attach thereto for the consideration of the collector, a statement setting out fully the nature and pur- pose of the organization, the source of its income, what dis- position is made of it, and particularly of any surplus which it may receive over and above its reasonable needs. If the collector is in doubt, he will refer the statement and return to the Commissioner of Internal Revenue for de- cision, and withhold listing for assessment until a decision is reached. — Treasury Decision 2090 ; also. Art. 79, Reg. 33, Revised. ^ 630 — Exemption Established. When a corporation or organization has established its right to exemption under any of the paragraphs of Section 11 of this title, it will be unnecessary for it to make a return or to make any further showing thereafter with respect to its status under the law, unless it changes the character of its organization or the purpose for which it was originally created. (Exempt corporations are enumerated in Section 231 of the Revenue Act of 1918.) Collectors will keep a list of all corporations whose ex- emption is conditional, to the end that they may occasionally inquire into their status and ascertain whether or not they are violating the conditions upon which their exemption is predicated. — Art. 80, Reg. 33, Revised. ^531 — Exempt Corporations. In cases wherein corporations have, by affidavit or other- wise, clearly established the fact and satisfied collectors of internal revenue that they are exempt from the require- ments of the Federal income tax law, or are defunct, dis- solved, or obsolete, and are no longer carrying on any busi- CORPORATIONS— Continued. EXEMPT ness and have no property or income, returns will not be required of them after such condition has been clearly es- tablished. But one showing of this character as to each such particular corporation will be required unless it shall later appear that any such corporation shall have such in- come within the meaning of the law as brings it within its requirements. — Treasury Decision 2137. See also H 528. ^ 532 — Society or Association Subject to Exemption Defined. A society or association "operating under the lodge sys- tem" is considered to be one organized under a charter or dispensation, with properly appointed or elected officers, with an adopted ritual or ceremonial, holding meetings at stated intervals, and supported by fees, dues or assessments. See H 522. 1i SSa— Clubs. All clubs are not exempt from the provisions of the in- come tax law, even though not operated for profit. A club desiring to be registered as an exempt organization should file with the Commissioner of Internal Revenue a copy of its charter, or an affidavit of its principal officer, setting forth the nature of its organization, the purpose for which organized, the source, if any, from which it derives income, and the disposition made of such income as is received by it for consideration and determination as to whether or not it comes within the class of organizations held to be exempt under the provisions of paragraph G of the income tax law. — Treasury Decision 2029; also see Tf 522. U 534— Social Clubs. Social clubs organized and operated exclusively for pleas- ure, recreation, and other non-profitable purposes are ex- empt from the tax, provided no part of any net income which they receive inures to the benefit of any private stockholder or individual. This exemption will reach practically an social arid recreation clubs which are supported by member- ship fees, dues, and assessments. 343 CORPORATIONS— Continued. EXEMPT If a club, by reason of the comprehensive powers granted in its charter, engages in traffic, in agriculture, or horti- culture, in the sale of real estate, timber, etc., for profit, it will be held that such club is not organized and operated exclusively for pleasure, recreation, or social purposes. It thus becomes a business or commercial enterprise, and any profit realized from such activities is subject to the tax im- posed by this title, and the club so operated must make returns of annual net income. — Art. 72, Reg. 33, Revised. ^ 535 — Cemetery Companies Organized for Benefit of Their Members Exempt. A cemetery company having a capital stock represented by shares, or which is operated for profit or for the benefit of others than its members, does not come within the ex- empted class, and will be required to make returns of an- nual net income and pay any income tax thereby shown to be due. In the case of such company a reserve set aside out of profits as a "maintenance fund'' is not deductible from gross income, and any accretions to such fund will be held to be income and, as such, must be returned by the corporation. The expenses of maintenance will be deductible as they are paid. — Art. 71, Reg. 33, Revised. 1J535(a) — Co-operative Dairies and Like Organizations. Co-operative dairies and like organizations do not fall within the classes of organizations enumerated in Tf 520 to 541 as exempt, and are required to make returns of an- nual income. — Treasury Decision 1996; also see 536. \\ 536 — Co-operative Dairy Defined. Co-operative dairy companies or associations not having capital stock and engaged in collecting milk and disposing of the same or the products thereof, and distributing the proceeds of the business, less necessary operating expenses, among their patrons, upon the basis of the quantity of butter fat in the milk furnished by such patrons, are held to be exempt from the tax imposed by this title. If, however, a dairy company purchases milk at k stipu- lated price and disposes of the same, or its products, through 844 CORPORATIONS— Continued. EXEMPT sale or otherwise, at a profit, and such profit inures to the benefit of the company or its members, on any basis other than the butter-fat content of milk furnished, such com- pany will come within the requirements of the law, and will be subject to the tax. — Treasury Decision 1996; also. Art. 76, Reg. 33, Revised. If 537 — Co-operative Associations Defined. Co-operative associations, in order to come within the ex- emption provided in paragraph "eleventh" must establish to the satisfaction of the collector or Commissioner of Internal Revenue the fact that, for their own account, they have no net income, their business being to market the products of their members, and that the entire proceeds of such mar- keting, less necessary selling expenses, are turned back or paid to the members on the basis of the quantity of produce furnished by them — quality and grade being considered — as the purchase price of such produce. If in the course of their business such associations pur- chase for cash at a stipulated price articles of produce with a view to selling them for gain, it will be held that such as- sociations are organized for profit and such associations will be required to make returns of annual net income and in- clude therein, for the purpose of the tax, all income derived from such transactions (Treasury Decision 2090). If amounts paid to members are based solely upon the quantity of produce furnished, such amounts may be deducted from the gross proceeds of sales, and the taxable net income will be the amount of earnings passed to surplus, or distributed or distributable among members on the basis of their stock holdings. — Art. 75, Reg. 33, Revised. If 538 — Foreign Governments Not Taxable. The income of foreign governments received from invest- ments in the United States in stocks, bonds, or other domes- tic securities, owned by such foreign governments, or from interest on deposits in banks in the United States of moneys belonging to such foreign governments, or from any other source within the United States, shall not be subject to the tax levied under this Act. CORPORATIONS— Continued. EXEMPT ^ 539— When Income from Public Utilities Is Not Taxable. The income derived from any public utility or from the exercise of any essential governmental function, which income accrues to any State, Territory, the District of Co- lumbia, or any political subdivision of a State or Territory or any income accruing to the government of any possession of the United States, or any political subdivision thereof — shall not be subject to the tax imposed by this Act. Whenever any State, Territory, or the District of Co- lumbia, or any political subdivision of a State, or Terri- tory, shall have, prior to September 8, 1916, contracted in good faith with any person or corporation to acquire, con- struct, operate, or maintain a public utility, no income tax pursuant to this Act shall be levied upon the income derived from the operation of such public utility, so far as the as- sessment and payment of such tax will impose a loss or burden upon such State, Territory, District of Columbia, or political subdivision, but the person or corporation is not re- lieved from the payment of the tax upon that portion of the income accruing to him, or it, under such contract. ^540 — Public Utility, With Mortgage Indebtedness Purchased by a Municipality. Where a municipality purchases a public utility subject to a mortgage, the mortgage retains its original character, even though the municipality assumes the mortgage indebt- edness and pays the interest thereon. Therefore, the in- debtedness secured by such mortgage is not an obligation of the municipality within the meaning of the income tax law. — (See ^'Mortgage Property Purchased Subject To.") — Treasury Decision 2090. TI 541 — Partnerships Not Taxable as Corporations. Ordinary copartnerships are not, as such, subject to the tax imposed by this Act, but the individual members of any such partnership are liable for income tax only in their in- dividual capacity on their respective shares of the earnings of such partnership,, whether such earnings be distributed or not. 346 CORPORATIONS—Continued. CAPITALIZATION ^ 541 (a) — Definition of Personal Service Corporation. The term "personal service corporation" means a corpora- tion whose income is to be ascribed primarily to the activi- ties of the principal owners or stockholders who are them- selves regularly engaged in the active conduct of the affairs of the corporation and in which capital (whether invested or borrowed) is not a material income-producing factor; but does not include any foreign corporation, nor any corpora- tion 50 per centum or more of whose gross income consists either ( 1 ) of gains, profits, or income derived from trading as a principal, or (2) of gains, profits, commissions, or other income, derived from a government contract or contracts made between April 6, 1917, and November 11, 1918, both dates inclusive. CAPITALIZATION. ^ 542--What Constitutes Paid-Up Capital Stock. Full amount of stock, as represented by the par value of the shares issued, is to be regarded as the paid-up capital stock, except when such stock is assessable on account of deferred payments, or payable in installments, in which case the amount actually paid on such shares will constitute the actual paid-up capital stock of the corporation. — Art. 181, Reg. 38, Revised. U 543— Paid-Up Capital Stock— Definition. For the purpose of income tax corporations must report total par value of its stock, both common and preferred, outstanding at close of year. Stock outstanding at the close of year and upon the basis of which dividends are or may be paid is held to be paid-up capital stock within meaning of law. Immaterial whether stock be paid for in cash, prom- issory notes or other assets. The fact that notes are given in payment of the stock issued and that notes have not been paid in full at time of return is immaterial. — Treasury De- cision 2137. ^ 544 — Capital of a Corporation. The amount received by a corporation for the original issue and sale of its capital stock is held to be the capital of 347 CORPORATIONS— Continued. INCOME the corporation. In cases where the stock, as originally is- sued, is sold at a price greater or less than the par value, neither the premium nor the discount will be taken into ac- count in determining the net income of the corporation for the year in which the stock is sold. This is purely a capital transaction and the income is neither increased nor de- creased by reason of the sale, per se, of the stock at a price greater or less than its par value. — Treasury Decision 2090 ; also see If 542. If 545 — Donations to Corporations of Capital Stock. If, for the purpose of enabling a corporation to secure working capital, or for any other purpose, the stockholders donate or return to the corporation to be resold by it certain shares of stock of the company previously issued to them, the sale of such stock will be considered a capital transac- tion, and the proceeds of such sale will be treated as capital and will not constitute income to the corporation. — Art. 99, Reg. 33, Revised. INCOME. For Definition of Gross Income, see H 559. tl 546— Basis of Tax. The corporation income tax of 12 per cent, apphes to the net income received by every taxable corporation in the calendar year 1918. If 547— Fiscal Year. In the case of a corporation making return for a fiscal year beginning in 1917 and ending in 1918, its income tax for the first taxable period under the Revenue Act of 1918 shall be the sum of (1) the same proportion of a tax for the entire period computed under Title I of the Revenue Act of 1916 (Income Tax) as amended by the Revenue Act of 1917 and under Title I. of the Revenue Act of 1917 (War Income Tax), which the portion of such period falling within the calendar year 1917 is of the entire period, and (2) the same proportion of a tax for the entire period 348 CORPORATIONS— Continued. .INCOME computed under this title at the rate for the calendar year 1918 which the portion of such period falling within the calendar year 1918 is of the entire period. In computing the tax as above provided, the tax com- puted for the entire period under Title II. of the Revenue Act of 1917 (War Excess-Profits Tax) shall be credited against the net income computed for the entire period under Title I. of the Revenue Act of 1916 as amended by the Revenue Act of 1917 and under Title I. of the Revenue Act of 1917, and the tax computed for the entire period under Title III. of this Act (War-Profits and Excess-Profits Tax) at the rates prescribed for the calendar year 1918 shall be credited against the net income computed for the entire period under this Title. In the case of a personal service corporation the amount to be paid shall be only that specified in clause (1). Any amount heretofore or hereafter paid on account of the tax imposed for such fiscal year by Title I. of the Rev- enue Act of 1916 as amended by the Revenue Act of 1917, and by Title I. of the Revenue Act of 1917, shall be credited against the payment of the tax for such fiscal year by the Revenue Act of 1918, and if the amount so paid exceeds the amount of the tax imposed by said Act, or in the case of a personal service corporation the amount resulting from clause (1), the excess shall be credited or refunded in ac- cordance with the provisions of Section 252. See If 634 (a) . ^ 548— Credits. The above tax is levied upon the net income in excess of the following credits as outlined in Section 236. In the case of a domestic corporation a specific exemption of $2,000. The amount received as interest upon obligations of the United States and bonds issued by the War Finance Cor- poration, which is included in gross income under Section 233. The amount of any taxes imposed by Title III for the same taxable year (War-Profits and Excess-Profits Tax), ex- cept in the case of a corporation which makes a return S40 CORPORATIONS— Continued. INCOME for a fiscal year beginning in 1917 and ending in 1918 in computing the tax for such fiscal year as provided by Section 205 (a) the tax computed for the entire period under Title II. (war-profits tax) of the Revenue Act of 1917 shall be credited against the net income computed for the entire period under Title I. (Income Tax) of the Revenue Act of 1916 as amended by the Revenue Act of 1917, and under Title I. (Income Tax) of the Revenue Act of 1917, and the tax computed for the entire period under Title III. (War-Profits and Excess-Profits Tax) of the Rev- enue Act of 1918 at the rates prescribed for the calendar year 1918 shall be credited against the net income computed for the entire period under the corporation income tax of the Revenue Act of 1918. ^ 549 — How Determined. The following definitions and rules are given for deter- mining the gross income of various classes of corporations : ^ 550 — Banks and Financial Institutions. Gross income of banks and other financial institutions consists of the total revenue received within the year for which the return is made frofn the operation of the business, including income, gains, or profits from the sale of capital assets and from all other sources. In cases where securities or other assets, real, personal, or mixed, acquired prior to March 1, 1913, are disposed of during the year, the gain or loss thereon will be based upon the difference between the price at which disposed of and the fair market price or value of such assets as of March 1, 1913, or the difference between the price at which disposed of and the cost if acquired subsequent to that date. — Art. 90, Reg. 33, Revised. Tf551 — Insurance Companies. Gross income of insurance companies consists of the total revenue derived from the operation of the business, includ- ing income, gains, or profits from all other sources, as shown by the entries on the books of account within the calendar or fiscal year for which the return is made, except (1) such 350 CORPORATIONS— Continued. INCOME portion of any actual premium received from any individual policyholder as is paid back or ciredited to or treated as an abatement of premium of such policyholder within the tax- able year, and (2) mutual marine insurance companies shall include in gross income the gross premiums collected and received by them less amounts paid for reinsurance. If 552 — Other Income. All other income or earnings not hereinbefore referred to will form a part of and must be reported as taxable income. —Art. 242, Reg. 33, Revised. TI 553 — Income from Sale of Personal Property on the Installment Plan. It has been ascertained that dealers in personal property who sell on the installment plan adopt one of four ways of protecting themselves in case of default, namely: (1) A provision that title is to remain in the seller until the buyer has performed his part of the agreement. (2) A conveyance of title to the purchaser subject to a lien for the unpaid portion of the purchase price. (3) The conveyance to the purchaser and an immediate reconveyance by way of chattel mortgage to the seller. (4) Conveyance to a trustee in trust to hold the title pending performance of the contract and subject to its pro- visions. The purpose is the same in all of these transactions. In view of the fact that in a number of States it is held that the form first mentioned shall not be enforced accord- ing to its terms, but will be regarded as a sale with a chattel mortgage back to secure the unpaid purchase price, it is desirable that a uniform rule be estabHshed which will be equitable and applicable to all. The rule prescribed is that in the sale or contract for sale of personal property on the installment plan, whether or not title remains in the vendor until the property is fully paid for, the income to be returned by the vendor will be that proportion of each installment payment which the gross profit to be realized when the property is paid for bears to the gross contract price. If, for any reason, the vendee de- 8Si CORPORATIONS— Continued. INCOME faults in his installment payments and the vendor repos- sesses the property, the entire amount received on install- ment payments less the profit originally returned will be income to the vendor to be so returned for the year in which the property was repossessed. (This ruling amends Articles 117 and 120 of Regulations 33, Revised, relating to the Revenue Act of 1916, and re- vokes all previous decisions and rulings which are in conflict herewith. — ^Treasury Decision 2707.) ^ 554 — Cost of Manufactured Products. A m.anufacturing corporation may include as an element of the cost of manufactured products, the cost of the raw material, the cost of labor of the men who actually work on such products, as well as the cost of supervisory, of what may be denomiated as "unproductive" labor, such as that of the foremen, inspectors, overseers, etc., provided such ex- penditures are not separately deducted from gross income in the return of annual net income. The overhead charges referred to in Form 1031 should include the salaries of officers, clerk hire, and such other office expenses as do not have to do directly with the manu- facture of the product. — Treasury Decision 2152. ^ 555 — Miscellaneous Corporations. Gross income of miscellaneous corporations consists of the total revenue derived from the operation and management of the business and property of the corporation making the return, together with all amounts of income, including the income gains, or profits from all other sources, including dividends. — Art. 93, Reg. 33, Revised. 1} 556 — Operating Corporation Controlled by Stock Ownership. A railroad company operating leased or purchased lines as an integral part of its line or system, and keeping no sepa- rate books of account as to such leased or purchased line, and the income from the operation of which can not be segregated, shall include in its income all receipts derived therefrom, and if bonded or other indebtdnss of the leased or purchased line has been assumed by the operating com- 352 CORPORATIONS— Continued. INCOME pany, it may deduct from its gross income the interest paid on such indebtedness, provided the interest so paid plus the interest paid on its own indebtedness is not in excess of the hmit fixed by the law. In this event the leased or pur- chased line so long as it has a corporate existence will make return of annual net income setting out that on its own ac- count it has neither income nor expenses, and that both are taken up in the return of the operating company, naming it» ^ 557 — Lessor Must Make Return. If the leased or purchased line keeps separate books of account, or the income from its operations is, or can be se- gregated, or if the lessee or operating company pays it a cer- tain rental, or in lieu of rental pays a certain per cent, of dividends on its stock, interest on its bonds, taxes, etc., it (the lessor) will return the same as its income and will be subject to tax accordingly, and the lessee or operating com- pany will make its return as though it were in no way re- lated to the leased line. — Art. 125, Reg. 33, Revised. Tf 558 — Income from Real Estate Transactions. Sains and profits resulting from a real estate transaction are subject to income tax in so far as they represent actual net income for the year in which the transaction occurred. The amount of income to be returned for the purpose of the income tax in the case of the sale of capital assets is the amount received upon the sale of the property in excess of its original cost, provided both the purchase and sale of the property took place since March 1, 1913. If the property was acquired prior to March 1, 1913, the difference between the fair market value of that date and the selling price will be considered income to the corporation. In determining the amount of income to be accounted for on this basis the corporation will consider mortgages, mort- gage notes, or any other credits received in payment of the property as though they were cash, and if it should occur that the purchaser of any of the property should later de- fault in payment, the corporation will be entitled to take credit as a loss for the amount of loss actually sustained by reason of the default. 853 CORPORATIONS— Continued. INCOME In determining the cost of the property for the purpose of arriving at the profit realized upon the sale it will be permissible for the corporation to add to the initial cost such carrying charges as interest, taxes, insurance, etc., pro- vided such carrying charges have not been deducted from net income which the corporation may have had and re- turned for years subsequent to March 1, 1913, and prior to the date of the sale of the property.-^— Also see H 553. ^ 559 — Gross Income Defined. Gross income embraces not only the operating revenues but also income, gains, or profits from all other sources, such as rentals, royalties, interest, and dividends from stock owned in other corporations; and also profits made in other corporations ; and also profits made from the sale of assets, investments, etc. A true and accurate record of all income received, as well as of all disbursements or charges against income, should be kept, in order that it may be identified and verified by an internal-revenue officer if an examination of the books should be deemed advisable. — Art. 88, Reg. 33, Revised. II 560 — Earnings or Dividends from Subsidiary Companies Not Deductible. Every corporation, no matter how closely related, it may be to any other corporation, is required to make return of annual net income and to pay any income tax thereby shown to be due. Parent, holding, or other corporations must include in their gross income, and cannot deduct therefrom, any divi- dends or share of earnings which they may receive from a subsidiary, related, or any other corporation. The fact that the parent or holding company owns all the stock of the subsidiary company is immaterial and will not warrant such parent company in omitting or deducting dividends from gross income. The Federal income tax law fixes a specific rule by which the net income, for the purposes of the tax, is to be com- puted. That rule makes no provision for the exclusion or deduction from the taxable income of dividends received. — Treasury Decision 2090. 8M CORPORATIONS— Continued. INCOME The Federal income tax law .specifically sets out that there shall be returned as gross income all income received from all sources during the year for which the return is made, and it specifically enumerates the items which may be allowably deducted from such gross income. There is no provision of the law whereby dividends received from other corporations may be excluded from gross income. Each corporation is a separate and distinct entity and must return, for the purposes of the tax, the income which it receives (except interest on obligations of a State or its political subdivisions or on the obHgations of the United States or its possessions), regardless of the source from which such income is received or regardless of the fact that a portion of such income may constitute dividends from other corporations subject to tax. — Treasury Decision 2137. If a corporation shall have returned as income, interest received on bonds, the interest upon which the debtor cor- poration had agreed to pay without deduction of income taxes, and if the debtor corporation shall have actually paid the income tax assessable on such interest income, it will be permissible for the corporation receiving such interest to take credit against the tax assessable on the basis of its net income returned, for the amount of tax paid thereon by the debtor corporation. — Art. 199, Reg. 33, Revised. H 561 — Dividends — Deductions from Gross Income. When a company composed of two stockholders divide profits between them, calHng it compensation, same cannot be deducted as expense of business. Money paid out under those circumstances is equivalent to dividends and must be treated as income of the corporation. Tf 562 — Interest on Exempt Bonds, Corporation. Interest on State, municipal and United States bonds received by corporations is not taxable to the corporation for the purposes of the Corporation Income Tax. Upon amalgamation with other funds of the corporation such income loses its identity. When distributed to stockholders as a dividend, the entire amount of the dividend is subject 855 CORPORATIONS— Continued. INCOME to inclusion in returns of income for the purposes of the income tax. The foregoing holds true for scrip payments of interest. —Art. 4, Reg. 33, Revised. fl 563 — Sinking Fund Reserve. When a corporation sets aside a part of its earnings for the purpose of creating a sinking fund with which to retire its bonded or other indebtedness, the annual additions to such funds are not allowable deductions from gross income as or in lieu of depreciation or on any other account. The earnings thus set aside are an asset of the corporation and any accretion thereto must be accounted for as income. — Treasury Decision 2161. This ruling will not, however, forbid the deduction from gross income of a reasonable allowance for depletion of natural deposits even though the amount so deducted be used in whole or in part in the payment of its bonded or other indebtedness. — Art. 166, Reg. 33, Revised. 5| 564 — Sinking Funds Invested in Bonds of Corporation. If the trustees of a sinking fund established by a corpora- tion have invested the amount of the sinking fund reserve or any portion of it in the bonds of the corporation and such corporation pays to the trustees the interest on these bonds, such corporation will be permitted to deduct such interest from its gross income, provided the amount of the interest thus paid, plus the interest on any other outstand- ing indebtedness which it may have, does not exceed the limit fixed by law. The interest paid to the trustees, to- gether with all other earnings on investments made by the trustees of the sinking fund, must be included in the gross income of the corporation. — Treasury Decision 2161; also Art. 189, Reg. 33, Revised. ^ 565 — Voluntary Payments by Stockholders. In cases wherein a corporation requires additional funds for conducting its business and obtains such needed money through voluntary pro rata payments by its stockholders, and such amounts received are credited to its surplus ac- count or to a special capital account, the amounts so re- 866 CORPORATIONS— Continued. INCOME ceived will not be considered income, although, as repre- senting this additional fund, there is no increase in out- standing shares of stock or liabiHty of the corporation. The payments under such circumstances are in the nature of voluntary assessments upon, and represent an additional price paid for, the shares of stock held by the individual stockholders, and will be treated as an addition to and as a part of the operating capital of the company. — Art. 96, Reg. 33, Revised. ^ 566— -Treasury Stock—When Taxable. Treasury stock, wherever and whenever that term is used in connection with the accounts of the corporation or for income-tax purposes, will be held to mean stock which had been previously issued by the corporation and which had been repossessed by it through purchase or otherwise and then carried on its books as an asset. If such stock is resold at a price in excess of its cost upon repossession, such excess shall be returned as income for the year in which resold. Unissued stock, which had been retained by the corporation for the purpose of future sale, will not, for the purpose of the income tax, be considered "Treasury stock," and when sold no part of the proceeds of such sale will be considered taxable income. Nor will there be any deductible loss if such stock is sold at a price less than par. —Art. 98, Reg. 33, Revised. ^ 567 — Gifts to Corporation — Income. The value or amount of a gift to a corporation is held to be income to such corporation and should be returned as such for the year in which the gift is received. The pro- vision of the Act of October 3, 1913, which exempts gifts, bequests, etc., from the tax imposed by the Act applies to individuals and not to corporations. — Treasury Decision 2090. ]\ 568 — Bonds — Interest On. The exchange of interest coupons for funding bonds is a payment of interest on the bonds and the income tax should be imposed and paid upon such interest as income for the year in which it matures and such payment is made, 357 CORPORATIONS— Continued. INCOME and in the absence of proper claim for exemption the tax should be deducted and withheld on the amount repre- sented by the coupons. — Treasury Decision 2090. ^569 — Income from Damages Recovered. When a corporation as a result of suit or otherwise se- cures payment for damages which it may have sustained, and the amount of such payment is in excess of an amount necessary to make good the damage or damaged property, the amount of such excess shall be considered and returned as income for the year in which received. If the entire or an estimated amount of the damage shall have been previ- ously charged off and deducted from gross income, then the amount recovered shall be returned as income. If the amount recovered is less than the damage sustained or less than an amount necessary to make good the damage, the difference between the actual amount of damage sus- tained and the amount recovered will be deductible as a loss. —Art. 94, Reg. 33, Revised. 11 570— Sale of Patents. A corporation disposing of patents by sale, should de- termine the profit or loss arising therefrom, by computing the difference between the selling price and the cost, or value as of March 1, 1913, if acquired before that date. The apparent profit or loss should be increased or decreased, as the case may be, by the amounts deducted since March 1, 1913, as a return of capital invested in such patents. — Art. 109, Reg. 33, Revised. T[ 571 — Exchange of Property for Stock. In cases wherein property was taken over in exchange for the capital stock of a corporation at a par value in excess of the fair market value of the property, and such property should be later sold, it will be necessary to ascer- tain as nearly as possible the fair market value of the property at the time it was taken over or as of March 1, 1913, if acquired before that date, and any excess over this ascertained fair market value at which the property 358 CORPORATIONS— Continued. INCOME is sold will be held to be profit or income to the corporation for the year in which the sale was made.^Art. Ill, Reg. 33, Revised. If 572 — Excess Value. Similar action may be taken in cases wherein corpora- tions acquire property prior to March 1, 1913, for a mere nominal sum and which had, as of March 1, 1913, a value greatly in excess of such nominal sum. A careful estimate of the fair market value of such property, as of March 1, 1913, may be made and set up as the capital invested in the property, and if such property is thereafter disposed of at a price in excess of such fair market value, the amount so in excess will be treated as income to be accounted for in preparing the return of annual net income of the year in which the property is sold. The value of the property fixed in the manner and for the purpose hereinbefore in- dicated will be subject to the approval of the Commis- sioner of Internal Revenue. If the property was acquired subsequent to March 1, 1913, the amount for which it is later sold or disposed of in excess of the cost price, regardless of the fact that it may have been acquired for a mere nominal price, will con- stitute income for the year in which the property was disposed of and must be so returned. — Art 112, Reg. 33, Revised. ^ 573--Royalties from Patent Rights. Royalties received by a corporation in accordance with a contract by which it has assigned the patent rights to manufacture machines, etc., are income and should be so accounted for. The owner of the patent may deduct from gross income each year, until the capital invested therein is extinguished, a sum ascertained by dividing the cost of the patent by the number of years constituting its life or by a number representing the years of its life remaining after the date of acquirement. — Art. 113, Reg. 33, Revised. Tf 574 — Bank Discounts. In cases wherein banks or other corporations loan money by discounting bills or notes, one of two methods shall be 359 CORPORATIONS— Continued. INCOME used in determining the amount of discount that is to be reported as income, namely (1) if the bank or corporation makes a practice of crediting such discount directly to a "discount account" or to profit and loss, the total amount thus credited during the year shall be considered income and shall be so reported, regardless of the fact that a por- tion of this amount may represent discount paid in advance and not then earned ; (2) if the bank or corporation follows the practice of crediting such discount to an "unearned discount account," and later, as the discount becomes earned, debits the unearned account and credits an "earned discount account" with the amount so earned, the total amount credited to the "earned discount account" during the year shall be considered income and shall be so returned. The corporation having income of this character should state in a memorandum attached to its return which of the two methods was used in determining the amount of discount returned as income. — Art. 114, Reg. 33, Revised. ^ 575 — Income from Sale of Capital Assets. If a corporation sells its capital assets in whole or in part, it will include in its gross income for the year in which the sale was made an amount equivalent to the excess of the sales price over the fair market price or value of such assets, as of March 1, 1913, if acquired prior to that date, or over costs if acquired subsequent to that date. If the purchase price is paid with stock issued by a pur- chasing company, the purchase price will be the actual value at the time of the stock issued in payment for such assets. —Art. 101, Reg. 33, Revised. If 576 — Capital Assets, Value of; When Exchanged for Capital Stock. In cases wherein property was taken over in exchange for the capital stock of a corporation at a par value greatly in excess of the true value of the property, and such prop- erty should be later sold, it will be necessary to ascertain as nearly as possible the true value of the property at the time it was taken over, and any excess over this ascertained 3«Q CORPORATIONS— Continued. INCOME true value at which the property is sold will be held to be profit or income to the corporation. Similar action may be taken in cases wherein corpora- tions acquire property for a mere nominal sum and which had at the time of its acquirement a value greatly in excess of such sum. A careful estimate of the value of such property at the time it was acquired may be fixed and set up as the value representing the cost of the property, and any excess over such fixed value at which such property may be thereafter disposed of will be treated as income to be accounted for in accordance with the rules of this de- partment in the case of the sale of capital assets. The value of the property fixed in the manner and for the purpose hereinbefore indicated will bei subject to the ap- proval of the Internal Revenue Bureau. — Treasury Decision 2161. For the purpose of determining the amount of profit or loss arising from the sale of capital assets acquired prior to March 1, 1913, which shall be taken into account by corporations in making their returns of annual net income, the gain or loss is represented by the difference between fair market value of such assets, as of March 1, 1913, and the selling price. To any gain thus apportioned and to be included in income there should be added any amount, or amounts, which had been charged against and deducted from gross income since March 1, 1913, on account of de- preciation and which had not been paid out in making good the depreciation — that is, any amount charged off later than March 1, 1913, on account of the depreciation of the assets sold and not used to make good such depreciation shall be added to the gain apportioned to these years and will be included in the income of the year in which the property was sold. Likewise, for the purpose of a deduc- tion from gross income of the year in which the assets were sold, loss resulting from any such sale, apportionable to the years subsequent to March 1, 1913, will be reduced by the amount of the unused portion of the depreciation charged off with respect to such assets March 1, 1913. — Treasury Decision 2077. 361 CORPORATIONS— Continued. INCOME This ruling, in so far as it relates to depreciation, applies only to such tangible property as is subject to wear and tear, exhaustion and obsolescence, and is not to be con- strued as recognizing any gain or loss due to jfluctuations in the market value or arbitrary changes in the book value of securities and like assets, the gain or loss with respect to which will be determined only when such assets mature, or are sold or disposed of — that is, when there is a com- pleted, a closed, transaction. — Treasury Decision 2005 and 2130. H 577 — Carrying Charges Part of the Cost of Assets. The foregoing is not intended to be so constructed that carrying charges, if they consist of such expenditures as constitute allowable deductions from gross income, are to be added to the cost of the property if there is a gross income from which such charges as constitute allowable deductions may be deducted. It is intended, however, that in the case of a holding or developing company which has not yet reached the stage of having any income of con- sequence resulting from its corporate operations, the carry- ing charges or other excess over the incidental income re- ceived may be added to and made a part of the cost of the property. As a general proposition involving the acquirement and holding of property for future sale, which property was acquired prior to the incidence of the tax and from which property there is but a nominal income, insufficient to meet the carrying charges, it would be proper for the corpora- tion to add to the initial cost of the property the carrying charges, such as interest, insurance and taxes actually paid, and from that amount deduct the incidental income which may have been received between the date of purchase and the date of the incidence of the tax. The result then shown will be the cost of the property or the amount to be excluded from the proceeds as capital when the property is sold. — Treasury Decision 2137. ^578 — Sale to Other Corporation. In determining the profits realized or the loss sustained upon the sale of capital assets by one corporation to an- CORPORATIONS— Continued. INCOME other, payment therefor being made in the stocks or bonds of the purchasing corporation, the profit or loss, as the case may be, from such sale will be ascertained upon the basis of the difference between the cost of such assets to the seller, in case they were acquired subsequent to March 1, 1913, or the fair market value as of March 1, 1913, if acquired prior to that date, and the fair cash value of the stock or bonds at the time the sale was made. — Treasury Decisions 2077 and 2137; also Art. 118, Reg. 33, Revised. 11 579 — Sale by Subsidiary to Parent Corporation. Where a subsidiary or other corporation sells or trans- fers its assets to a parent or other corporation, accepting in exchange therefor the stock or bonds of the purchasing corporation, the question of gain or loss resulting from this transaction will be determined upon the basis of the dif- ference between the cost or market value as above indi- cated of the assets sold and the actual value of the stock or bonds given in exchange therefor. Any gain or loss thus ascertained as resulting from such a transaction will be added to or deducted from the entire gross income, as the case may be, of the selHng corporation in the year in which the capital assets were sold. — Treasury Decisions 2077 and 2137; also. Art. 119, Reg. 33, Revised. ^ 580 — Stock Issued for Stock of Other Corporation. In a case wherein a corporation acquires from stock- holders the stock of another corporation, giving in exchange therefor its own stock, it is held that the transaction is one by which the corporation acquiring the stock becomes the sole stockholder of the other corporation. As a result of this transaction no income accrues to the corporation whose stock is thus acquired. Neither will any income accrue to this corporation if later the holding corporation should cause the assets of the underlying company to be trans- ferred to it for mere nominal consideration. If, however, one corporation buys the assets of another and issues direct to the selling company its own capital stock in payment for the assets acquired, the transaction 363 CORPORATIONS— -Continued. INCOME will be treated by the selling company as a sale of its assets, and the question as to whether profit or loss results from the sale will depend upon whether or not the value of the stock taken in payment for the assets is in excess of the fair market price or value as of March 1, 1913, of the assets sold or of their cost accordingly as they were acquired by the selhng company prior or subsequent to that date. If the value of the stock is so in excess, the amount of such excess will be taxable income for the year in which the assets were sold and must be so returned. If the excess over values as of March 1, 1913, or over cost, as the case may be, includes any surplus earned since March 1, 1913, upon which the income tax has been paid, the excess or profits resulting from the sale may be reduced by the amount of such tax-paid surplus. If the purchasing corporation takes over all the assets including accounts receivable, bills receivable, surplus, etc., of the selling corporation and assumes its liabilities, the amount so assumed will be considered a part of the purchase price, and to the extent that the entire purchase price ex- ceeds the cost or value, as of March 1, 1913, as the case may be, of the assets disposed, income will accrue to the selling company. — Art. 124, Reg. 33, Revised. t[581 — Shrinkage in Value of Securities Written Down by Order of Comptroller of Currency or State Banking Department Not Allowable Deduction. The fact that bonds and similar securities were written off at the direction of the Comptroller of the Currency or the State Banking Department is not material. A mere book entry does not constitute either a loss or a gain for the purpose of the income tax. The fact that bonds were written off does not necessarily imply that they are a total loss, nor is this act a conclusive proof that any loss oc- curred during the year for which return was made. Losses of this character are only ascertainable when the securities mature, are disposed of, or cancelled. — Treasury Decision 2152. 364 CORPORATIONS— Cont'd DEDUCTIONS— Expenses ^ 582 — Inventories of Merchandise and Securities. That whenever in the opinion of the Commissioner of Internal Revenue the use of inventories is necessary in order clearly to determine the income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the Com- missioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade oi' business and as most clearly reflect- ing the income. IT 583 — Premium or Discount on Sale of Capital Stock. See "Capital of a Corporation," T[ 544. If 584— Void— [Ed.] If 585^ — Interest to Be Included in Gross Income. A corporation doing a brokerage business, buying securi- ties for its customers, who paid only a part of the purchase price, paying interest on balances, the s corporation also paying for the securities purchased only part of the pur- chase price and owing balances on which it paid interest, including in return of gross income the difference between the interest received and the interest paid, made incorrect return. Such interest received from customers should be included in gross income. — Decision of Court. DEDUCTIONS. If 588 — Net Income — How Ascertained. In computing the net income of a corporation subject to the tax imposed by Section 230 there shall be allowed as deductions : (The deductions must in all cases be such as are author- ized and within the limits fixed by law. — Art. 127, Reg. 33, Revised.) 11 587 — Expenses. Al] the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other com- pensation for personal services actually rendered, and in- 365 CORPORATIONS— Cont'd DEDUCTIONS— Expenses eluding rentals or other payments required to be made as a condition to the continued use or possession of property to which the corporation has not taken or is not taking title, or in which it has no equity. 11 588— When Deductible. Expenses of operation and maintenance shall include all expenditures for material, labor, fuel, and other items en- tering into the cost of the goods sold or inventoried at the end of the year, provided such expenditures have not been considered in determining the cost of goods or materials or purchases thereof during the year, when the income derived from operations is ascertained through inventory, and all other disbursements necessary to the operation of the busi- ness, except such as are required by the Act to be segre- gated and stated separately in the return. Expenditures which are taken into account in determining the cost of products, finished or unfinished, are not to be again deducted as expenses of operation and maintenance. — Art. 129, Reg. 33, Revised. ^ 589— Cost of Material. In ascertaining expenses proper to be included in the de- ductions to be made under the item of "Expenses," corpora- tions carrying materials and supplies on hand should include in such expense the charges for materials and supplies only to the amount that the same are actually consumed and used in operation and maintenance during the year for which the return is made, provided that the cost of such material and supphes has not been taken into account in determining the net income for any previous year. If a corporation carries materials or suppHes on hand for which no record of consumption is kept or of which physical inventories at the beginning and end of the year are not taken, it will be permissible for the corporation to include in its expenses and deduct from gross income the total cost of such supplies and materials as were purchased during the year for which the return is made. — Art. 130, Reg. 33, Re- vised. 366 CORPORATIONS— Cont'd DEDUCTIONS— Expenses TI580 — Repairs. The cost of incidental repairs which neither add to the value of the property nor appreciably prolong its life, but keep it in an ordinarily efficient operating condition, may be deducted as expense, provided that the plant or property ac- count is not increased by the amount of such expenditures. Such repairs, to the extent that they arrest deterioration, should have the effect to reduce the depreciation charge otherwise deductible. — Art. 131, Reg. 33, Revised. ^ 591 — Depositors' Guarantee Fund. Banking corporations which, pursuant to the laws of the States in which they are doing business, are required to set apart, keep, and maintain in their banks the amount levied and assessed against them by the State authorities as a "Depositors* guarantee fund," may deduct from their gross income in their returns of annual net income the amount so set apart each year to this fund, provided that such fund, when set aside and carried to the credit of the State banking board or other duly authorized State officer, ceases to be an asset of the bank, but may be withdrawn in whole or in part, upon demand by such board or State officer to meet the needs of these officers, as required by State laws, in re- imbursing depositors in insolvent banks, and provided fur- ther that no portion of the amount thus set aside and cred- ited as returnable, under the existing laws of the State, to the assets of the banking corporation. If, however, such amount is simply set up on the books of the bank as a reserve to meet a contingent liabiHty, and remains an asset of the bank, it will not be deductible ex- cept as it is actually paid out as required by law and upon demand of the proper State officers. — Art. 146, Reg. 33, Revised. ^ 592 — Cost of Improvements. Where old machinery, equipment, etc., is replaced with new, the rule is that the cost of renewals with hke kind and quality is allowable, but excess cost is not an allowable de- duction from gross income. Amounts expended for im- 367 CORPORATIONS— Cont'd DEDUCTIONS— Expenses proving and adding to property, such as new buildings, shops, machinery and additions to equipment are to be in- cluded as income. — Treasury Decision 2210. ]\ 593 — Additions and Betterments. Amounts expended in additions and betterments or for furniture and fixtures which constitute an increase in capital investment and add to the value of the assets are not a proper deduction, but such expenditures when capitalized may be extinguished through annual depreciation deduc- tions, which latter deductions will be computed upon the basis of the cost and probable life of the property. — Art. 132, Reg. 33, Revised. ^ 584 — Asset s^ — Carrying Charges Part of the Cost of, When.— See If 577. Tf 595 — Salaries Paid Officers and Employes. In the case of salaries paid to officers and employes of corporations, there has been fixed no definite amounts which may be allowably deducted from gross income. Any amount representing a fair and reasonable compensation for the services rendered by the officers or employes will constitute an allowable deduction from gross income. For more detail as to allowable deductions for these items, see Treasury Decision 2696. ^ 596— -Definition of "Paid." The term "paid," for the purposes of the deductions and credits under the corporation income tax, means "paid or accrued" or "paid or incurred" and the terms "paid or in- curred" and "paid or accrued" shall be construed according to the method of accounting upon the basis of which the net income of the taxpayer is computed. ^ 597 — Charged Against Current Earnings. All expenses, including interest, taxes, and other neces- sary charges, incidental and necessary to the creation or pro- duction of the gross income or properly chargeable against the same, being deductible from the gross income, whether paid in cash or entered on the books as a liabiHty, can not, 368 CORPORATIONS— Cont^d DEDUCTIONS— Expenses if unpaid, be carried forward to be deducted from the gross income of a subsequent year. — Art. 127, Reg. 33, Revised. If 598 — Dividends — Deductions from Gross Income. When a company composed of two stockholders divides profits between them, calHng it compensation, same cannot be deducted as expense of business. Money paid out under those circumstances is equivalent to dividends and must be treated as income of the corporation. — See t[ 614. ]\ 599 — Holding or Development Company. Carrying charges part of the' cost of assets. — See If 577. ^ 600 — Spending Money. So-called "spending or treating money" actually advanced by the corporations to their traveling salesmen to be used by them as a part of the expense incident to selling the product of such corporations, is an allowable deduction in a return of income by such corporation. The deduction of such expenditures is conditioned upon a satisfactory show- ing that all the allowance claimed as a deduction was actu- ally expended for and was an ordinary and usual expense in- curred in selling the product or merchandise of the cor- poration. — Treasury Decision 2090 ; also Art. 133, Reg. 33, Revised. ^ 601 — Lobbying Expenses. Sums of money expended for lobbying purposes, the pro- motion or defeat of legislation, the exploitation of propa- ganda, and contributions for campaign expenses are held not to be an ordinary and necessary expense in the operation and maintenance of the business of a corporation, and are therefore not deductible from gross income in arriving at the net income upon which the income tax is computed. — Treasury Decision 2137 ; also Art. 143, Reg. 33, Revised. Tf 602— Earnings of Public Utility Paid to City, Etc. In case of a pubHc utility constructed, operated, or main- tained by a corporation under contract with any city. State, Territory, or the District of Columbia, with an agreement that a portion of the net earnings of such public utility shall be paid to the city, State, Territory, or the District of Col- 369 CORPORATIONS— Cont'd DEDUCTIONS— Expenses umbia, the amount so paid may be deducted by the pubHc utility company as a necessary expense of transacting busi- ness. — Treasury Decision 2090 ; also Art. 142, Reg. 33, Re- vised. ^ 603 — Expenses Incurred in Sale of Capital Stock. Any and all expenses incidental to or connected with the selling of the capital stock (common or preferred) of a cor- poration for the purpose of raising capital to be by it in- vested in property or employed in the business for which the corporation is organized are not an "expense of operation and maintenance" within the meaning of this title, and such expense is not an allowable deduction from the gross income, for the reason that such an expense is incurred in a capital transaction ; that is, the raising of capital to be invested or employed in the business. Such expense, like the discount at which the shares of stock may be sold, has the effect only to reduce the available capital of the corporation and cannot be used to reduce the income from operations ; that is to say, any expense incident to the bringing of capital into the company, whether it be a new or a going concern, can not be recouped out of or charged against the operating income. It is a capital loss or expense properly chargeable against the proceeds of the sale of the stock and reduces the capital rather than the earnings of the company. — ^Art. 145, Reg. 33, Revised. ^ 804 — Expenses Deductible by Tenant Corporations. In the case of corporations which occupy leased prem- ises under a lease contract which requires such corporations to make all necessary repairs or improvements, which re- pairs or improvements revert to the owner of the fee at the expiration of the lease, the tenant corporation is entitled to charge the cost of all such repairs and improvements to the expense of doing business. This expense of improvements, somewhat permanent in character, should, however, be pro- rated over the number of years constituting the term of the lease, and the amount deductbile from gross income of each year would be the aliquot part of the cost of such re- pairs and improvements. — Treasury Decision 2137. »70 CORPORATIONS— Cont'd DEDUCTIONS— Expenses If 605 — Additional Deductions by Insurance Companies. In addition to the other deductions from gross income enumerated herein, insurance companies are, under the pro- visions of the Revenue Act of 1918, allowed the following deductions : (a) The net addition required by law to be made within the taxable year to reserve funds (including in the case of assessment insurance companies the actual deposit of sums with State or Territorial officers pursuant to law as additions to guarantee or reserve funds) ; and (b) the sums other than dividends paid within the taxable year on policy and annuity contracts; In the case of corporations issuing policies covering life, health, and accident insurance combined in one policy issued on the weekly premium payment plan continuing for life and not subject to cancellation, in addition to the above, such portion of the net addition (not required by law) made within the taxable year to reserve funds as the Commis- sioner finds to be required for the protection of the holders of such policies only ; In the case of mutual marine insurance companies, there shall be allowed amounts repaid to policyholders on account of premiums previously paid by them, and interest paid upon such amounts between the ascertainment and the payment thereof ; In the case of mutual insurance companies (other than mutual life or mutual marine insurance companies) requir- ing their members to make premium deposits to provide for losses and expenses, there shall be allowed the amount oi premium deposits returned to their policyholders and the amount of premium deposits retained for the payment of losses, expenses, and reinsurance reserves ; ^ 605 (a) — Additions and Betterments to Property. Additions and betterments to property, such as expendi- tures for sidings or spur tracks, are not deductible. — Treas- ury Decision 2210. 371 -^^ CORPORATIONS— Cont'd DEDUCTIONS— Expenses ^ 60© — Cost of Improvements. Where old rails are replaced with new or heavier rails, wooden bridges and culverts with concrete and steel bridges and culverts, the rule is that the cost of renewals with like kind and quality is allowable, but excess cost is not allow- able as a deduction. — Treasury Decision 2210. U GOT — Expenditures Included in Income. Amounts expended for improving and adding to the prop- erty, such as building new stations and new shops, installing new machinery, and making additions to equipment, are included as income. — Treasury Decisions 2210. ff 008 — Maintenance Expense. Maintenance means the upkeep or preserving of the con- dition of the property to be operated and does not mean additions to the equipment, additions to the property, or improvements of the former conditions of the road. Such expense is therefore deductible. — Treasury Decision 2210. Tf 609 — Payment for Labor and Materials. Payment for labor and materials which go into the actual operating of the road and the property are deductible. — Treasury Decision 2210. ^ 61 — Interest Paid or Accrued Within the Year. The amount of interest paid or accrued within the taxable year on its indebtedness, except on indebtedness incurred or continued to purchase or carry obligations on securities (other than obligations of the United States issued after September 24, 1917) the interest upon which is wholly exempt from the normal tax under the income tax law. Law, page 76, line 15. f|611 — Bank and Trust Companies — Interest Deduction. Banks — Interest Deposits — Money Received for Investment. In the case of a bank, banking association, loan or trust company, interest paid within the year on deposits or on moneys received for investment and secured by interest- ^" 372 CORPORATIONS— ContM DEDUCTIONS—Expenses bearing certificates of indebtedness issued by such bank, banking association, loan or trust company shall be deducted from gross income. IJ 81 2— Taxes. Taxes paid or accrued within the taxable year imposed (a) by the authority of the United States, except income, war-profits and excess-profits taxes ; or (b) by the authority of any of its possessions, except the amount of income, war-profits and excess-profits taxes allowed as a credit under Section 238 ; or (c) by the authority of any State or Territory, or any county, school district, municipality, or other taxing subdivision of any State or Territory, not in- cluding those assessed against local benefits; (d) in the case of a domestic corporation, by the authority of any foreign country, except the amount of income, war-profits and excess-profits taxes allowed as a credit under Section 238: Provided, That in the case of obligors specified in subdivision (b) of Section 221 no deduction for the pay- ment of the tax imposed by this title or any other tax paid pursuant to the contract or provision referred to in that subdivision, shall be allowed. ^ G1 3 — General Expenses. Expenses of operation and maintenance shall include all expenditures for material, labor, fuel, and other items enter- ing into the cost of the goods sold or inventoried at the end of the year, and all other expenses incurred in the operation of the business except such as are ixaquired by the Act to be segregated in the return. — Art. 129, Reg. 33, Revised. ^ 61 4 — Bonuses or Additional Compensation. Special payments, sometimes denominated gifts or bon- uses, made by corporations, partnerships, or individuals to officers or employes, will constitute allowable deduction from gross income in ascertaining net income for the pur- pose of the income tax, when such payments are made in good faith and as additional compensation for the services actually rendered by the officers or employes. If such pay- ments, when added to the stipulated salaries do not exceed a reasonable compensation for the services rendered they 373 CORPORATIONS— Cont'd DEDUCTIONS— Expenses will be regarded as a part of the wage or hire of the officer or employe, and therefore an ordinary and necessary ex- pense of operation and maintenance, and as such will be deductible from gross income. Special payments made to officers or employes who are stockholders, in the guise of additional salaries or compen- sation, the amount of which is based upon or bears a close relationship to the stockholders of such officers or em- ployes or the capital invested by them in the business of the company, will be regarded as a special distribution of profits, or compensation for the capital invested, and not payment for services rendered. Payments under such latter conditions being in the nature of dividends, will not be deductible from gross income. Salaries of officers or employes who are stockholders will be subject to careful analysis, and if they are found to be out of proportion to the volume of business transacted, or excessive when compared with the salaries of like officers or employes of other corporations doing a similar kind or volume of business, the amount so paid in excess of reason- able compensation for the services will not be deductible from gross income, but will be treated as a distribution of profits. — Art. 138, Reg. 33, Revised; also see Treasury De- cision 2696. Tl 61 5 — Redemption of Trading Stamps. Corporations, mercantile or otherwise, which issue trad- ing stamps, coupons, etc., for the purpose of increasing their business, which stamps or coupons are redeemable in mer- chandise, may allowably deduct from gross income as a business expense the amount which such corporations actually expended for such stamps or coupons, and also the actual cost to the corporations of the merchandise given in redeeming the same. This rule contemplates that a reserve set up as a liability equal to the redemption value of the stamps or coupons issued is not, as such, an allowable deduction, the deduction being hmited to the cost of the stamps or coupons and the merchandise with which they are redeemed. — Art. 141, Reg. 33, Revised. 374 CORPORATIONS— Cont'd DEDUCTIONS— Expenses \\ 616 — Life Insurance in Favor of Corporations. That premiums paid on life insurance policies covering the lives of officers, employes, or those financially inter- ested in any trade or business conducted by an individual, partnership, corporation, joint-stock company or associa- tion, or insurance company, shall not be deducted in com- puting the net income of such individual, corporation, joint- stock company or association, or insurance company, or in computing the profits of such partnership. ^ 61 7 — Cost of Buildings on Leased Ground. The cost of erecting permanent buildings, or of making permanent improvements on ground leased by a company, is held to be an additional rental and is therefore a proper deduction from gross income, provided such buildings and improvements, under the terms of the lease, revert to the owner of the ground at the expiration of the lease. In such case, however, the cost will be prorated according to the number of years constituting the term of the lease and the annual deduction will be an aliquot part of such cost. — Art. 140, Reg. 33, Revised. ^ 61 8 — No Depreciation. The cost of the buildings being a rental charge and de- ductible on the prorated basis, the lessee corporation will not be permitted to deduct from gross income any depre- ciation with respect to such buildings, but the cost of in- cidental repairs necessary to keep them in an efficient con- dition for the purposes of their use, may be deducted as an expense of operation and maintenance. If, however, the life of the improvement is less than the life of the lease, the depreciation may be taken by the lessee, based upon the cost and life of the improvement. — Art. 140, Reg. 33, Revised. l[ 61 9 — Rental — Tenant Corporations Making Repairs, Etc. Tenant corporations which occupy premises under a lease which requires such corporations to make all necessary re- pairs or improvements, which repairs or improvements re- 375 CORPORATIONS— Cont'd DEDUCTIONS— Expenses vert to the owner at expiration of lease, is entitled to charge cost of such repairs, etc., to expense of doing business. For method of prorating such expense, see H 617.. H 620 — New Buildings, Permanent Improvements, Betterments, Etc. No deduction shall be allowed for any amount paid out for new buildings, permanent improvements, or better- ments, made to increase the value of any property or estate, and no deduction shall be made for any amount of expenses of restoring property or making good the exhaustion there- of for which an allowance is or has been made, except in the case of mines, oil, and gas wells, other natural deposits and timber. ti 621 — Commissions to Salesmen Paid in Stock. Commissions allowed salesmen, paid in stock, may be deducted as expense if so charged on the book at the actual value of such stock. li 622 — Additions and Betterments. Amounts expended in additions and betterments which constitute an increase in capital investment are not a proper deduction. — Art. 132, Reg. 33; Revised. II 623 — Compensation Paid in Stock. Compensation paid an employe in capital stock of the corporation may be deducted as an expense if so charged on books at the actual value of such stock, and the recipient of such stock, if he be a taxable person, will return such stock at the same value as income. — Art. 139, Reg. 33 ; Re- vised. 1[ 624 — Pensions. Amounts paid for pensions to retired employes, or to their families or others dependent upon them, or on account of injuries received by employes, or lump-sum amounts paid as compensation for injuries, are proper deductions as "ordinary and necessary expenses." Such deduction shall be limited to the amount not compensated for by insurance or otherwise. 376 CORPORATIONS— Cont'd DEDUCTION S-^Expenses No deduction shall be made for contributions to a pension fund the resources of which are held by the corporation, the amount deductible in such case being the amount actu- ally paid to the employe. — Art. 136, Reg. 33 ; Revised. ti 625 — Salary Paid After Death of Employe. When the amount of the salary of an officer or employe is paid for a limited period after his death to his widow or heirs, in recognition of the services rendered by the individ- ual, no services being rendered by the widow or heirs, such payment is not "ordinary and necessary" expense of trans- acting business and does not constitute an allowable deduc- tion.— Art. 137, Reg. 33 ; Revised. 1[ 626 — Special Compensation to Employes. When deductible and not deductible. — See H 614. Special payments made by a corporation as extra com- pensation to certain of its employes may be deducted from gross income, if it is clearly shown that such payments are made as compensation for services rendered. If so-called "compensation" is a gratuity or voluntary payment, for which no service is rendered, the amounts so paid are not deductible. In cases where the payments are made as compensation for services rendered, the employees receiving the same, if he be a "taxable person," will be required to include the amount of such compensation in his personal income tax return. — Treasury Decision 2152. |[ 627 — Donations Deductible — When. Donations made by a corporation for purposes connected with the operation of the property, when limited to char- itable institutions, hospitals or educational institutions, conducted for the benefit of its employes or their depend- ents, shall be a proper deduction as ordinary and necessary expenses. Such deduction should, however, be reduced by any amount repaid to the corporation by the employes. Donations which legitimately represent a consideration for a benefit flowing directly to the corporation as an inci- dent of its business are allowable deductions from gross 377 CORPORATIONS— Cont'd DEDUCTIONS— Losses income in ascertaining net income subject to the income tax ; for example, a street railway corporation donates a sum of money to an organization intending to hold a convention in the city in which it operates, with the expectation that the holding of such convention will augment its income through a greater number of people using the cars. In such case the donations would be an allowable deduction, the deduction to be reduced by any portion of the donation which may be returned to the corporation. — Art. 134, Reg. 33; Revised. H 628 — Donations Not Deductible. Donations made to employes and others, and which do not have in them the element of compensation, are consid- ered gratuities and are not allowable deductions from gross income as expenses of operation or maintenance or under any other item. — Treasury Decision 2090; also, Art. 135. Reg. 33, Revised. ^ 629 — Reserves for Insurance Not Deductible. Funds set aside by a corporation for insuring its own property are not a proper deduction, but if such funds are set aside, or a reserve therefor is set up, any loss actually sustained and charged to such funds or reserves may be deducted. — Art. 144, Reg. 33 ; Revised. 11 630— LOSSES. Losses sustained during the taxable year and not com- pensated for by insurance or otherwise. Law, page 76, line 52. ^031— When Deductible. The deduction for losses must represent losses not com- pensated for by insurance or otherwise actually sustained within the taxable year. In the case of the sale of assets — real, personal, or mixed — the loss will be the difference between the cost thereof, or the value as of March 1, 1913, if acquired before that date, and the price at which disposed of. When the loss is claimed through the destruction of property by fire, flood, or 378 CORPORATIONS— Cont'd DEDUCTIONS— Losses other casualty the" amount deductible will be the difference between the value as of March 1, 1913, or the cost of the property and the salvage value thereof, including in the latter value the amount, if any, that has been or should have been set aside and deducted in the current or previous years from gross income on account of depreciation and which has not been paid out in making good the depreciation sustained. 1[ 632— Mines, Oil and Gas Wells, Etc. In the case of mines, oil and gas wells, other natural de- posits, and timber, a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar conditions in each case, based upon cost including cost of development not otherwise deducted. In the case of such properties acquired prior to March 1, 1913, the fair market value of the property (or the tax- payer's interest therein) on thai: date shall be taken in lieu of cost up to that date. In the case of mines, oil and gas wells, discovered by the taxpayer, on or after March 1, 1913, and not acquired as the result of purchase of a proven tract or lease, where the fair market value of the property is materially dispro- portionate to the cost, the depletion allowance shall be based upon the fair market value of the property at the date of the discovery or within 30 days thereafter. Such reasonable allowance in all the above cases to be made under rules and regulations to be prescribed by the Commissioner with the approval of the Secretary. In the case of leases the deductions allowed by this para- graph shall be equitably apportioned between the lessor and lessee. ]\ 633 — Losses On Judgments. Any amount paid pursuant to judgment or otherwise on account of damages is deductible from gross income to the extent of, and when the amount is actually paid, less any amount of such damages as may have been compensated for by insurance. — Art. 158, Reg. 33 ; Revised. 379 CORPORATIONS— Cont'd DEDUCTIONS— Losses If 634 — Losses in Inventory— Previous — First Time Ascertained. (a) At the time of filing return for the taxable year 1918 a taxpayer may file a claim in abatement based on the fact that he has sustained a substantial loss (whether or not actually realized by sale or other disposition) resulting from any material reduction (not due to temporary fluctuation) of the value of the inventory for such taxable year, or from the actual payment after the close of such taxable year of rebates in pursuance of contracts entered into during such year upon sales made during such year. In such case pay- ment of the amount of the tax covered by such claim shall not be required until the claim is decided, but the taxpayer shall accompany his claim with a bond in double the amount of the tax covered by the claim, with sureties satisfactory to the Commissioner, conditioned for the payment of any part of such tax found to be due, with interest. If any part of such claim is disallowed then the remainder of the tax due shall on notice and demand by the collector be paid by the taxpayer with interest at the rate of 1 per centum per month from the time the tax would have been due had no such claim been filed. If it is shown to the satisfaction of the Commissioner that such substantial loss has been sustained, then in computing the taxes imposed by this title and by Title III. the amount of such loss shall be deducted from the net income, (b) If no such claim is filed, but it is shown to the satisfaction of the Commissioner that during the taxable year 1919 the taxpayer has sustained a substan- tial loss of the character above described, then the amount of such loss shall be deducted from the net income for the taxable year 1918 and the taxes imposed by this title and by Title III. for such year shall be redetermined accordingly. Any amount found to be due to the taxpayer upon the basis of such redetermination shall be credited or refunded to the taxpayer in accordance with the provisions of Section 252. 11 635— Bad Debts. Debts ascertained to be worthless and charged off within the taxable year. — Law, page 76, line 54. 380 CORPORATIONS— Cont'd DEDUCTIONS— Losses j[ 63S~-Bad Debts or Doubtful Accounts. * Losses which may be properly deducted from gross in- come on account of bad debts or doubtful accounts are those losses which have been definitely ascertained to have oc- curred and which were charged off during the year for which the return is made. It is not essential that the bad debt or account shall be proved worthless by legal proceed- ings before the deduction may be allowed but the corporation must not only be satisfied that the debt or account is worth- less, but must be able to satisfy the Commissioner or col- lector of internal revenue that the accounts charged off were definitely determined at the time to be worthless and that they had not been recognized as worthless or without value prior to the beginning of the year for which the re- turn is made. H 637— Bad Debts—Loss Must Be Definite. In the absence of legal proceedings to determine the col- lectibility of a debt or account, the question of whether or not it is an asset without value will depend largely upon the judgment of the creditor. The mere writing down of the value of an account does not constitute such a loss as may be allowably deducted. The deduction will be permis- sible only when the debt or account is written out of the assets of the corporation. — Art. 151, Reg. 33 ; Revised. If 638 — Bad Debts^ — Arising from Unpaid Wages, Etc. Bad debts arising from unpaid wages, salaries, rents and items of similar taxable income will not be allowed as de- ductions unless the income which they represent has been included in a return of gross income for the year in which the deduction as a bad debt is sought to be made or in a previous year and the debts themselves have been actually ascertained to be worthless and charged off. — Art. 8, Reg. 33; Revised. ^ 639 — Bad Debts Recovered. Bad debts or accounts charged off by a corporation be- cause of the fact that they were determined to be worth- less, and subsequently recovered, constitute income for the 381 CORPORATIONS— Cont'd DEDUCTIONS— Losses year in which recovered, regardless of the date when the amounts were charged off. Neither the date at which the debt was charged off nor the fact that it was or was not deducted from gross income in any return made for tax purposes, will in any way affect its character as income of the year in which recovered. — Art. 110, Reg. 33; Revised. ^ 640 — Voluntary Removal of Buildings. Loss due to the voluntary removal or demolition of old buildings, the scrapping of old machinery, equipment, etc., incident to renewals and replacements will be deductible from gross income, in an amount representing the differ- ence between the cost of such property demolished or scrapped and an amount measuring a reasonable allowance for the depreciation which the property had undergone prior to its demolition or scrapping ; that is to say, the de- ductible loss is only so much of the original cost, less sal- vage, as would have remained unextinguished had a reason- able allowance been charged off for depreciation during each year prior to its destruction. — Art. 155, Reg. 33 ; Revised. H 641 — Erection of New Buildings. When a corporation buys real estate, upon which is lo- cated a building or buildings, which it proceeds to raze, with a view to erecting thereon another building or buildings, it will be held that the corporation has sustained no deduct- ible loss by reason of the demolition of the old building or buildings. In such case it will be considered that the value of the real estate, exclusive of old improvements, is equal to the purchase price of the land and buildings. — Art. 156, Reg. 33; Revised. H 642--Void— [Ed.] ^ 043 — Loss Due to Retirement of Bonds. In a case wherein a corporation, under the terms of its in- denture, securing an issue of bonds is required annually or at certain specified periods to purchase and retire a certain number of its bonds and in doing so pays more than par for the bonds, the loss sustained is an allowable deduction 382 CORPORATIONS— Cont'd DEDUCTIONS— Losses from gross income for the year in which such purchase is made, under the following conditions: First. If the bonds were sold at par, then the loss is the difference between par and the price at which they were repurchased for retirement. Second. If the bonds were sold at a premium and such premium was accounted for as income for the year in which issued, then the difference between par and the repurchase price may be deducted as loss, but if the premiums at which the bonds were issued had not been carried into the income account then the loss to be claimed should be the difference between the price at which the bonds were sold and the price at which they were repurchased. Third. If the bonds were sold at a discount and the dis- count was charged against the earnings of the year in which issued, the difference between par and the repurchase price may be deducted as a loss, but if the discount on the bonds was prorated over the life of the bonds and the annual pro- portion charged against the yearly income, the amount to be charged off as a loss for the year in which the bonds are repurchased for retirement should be the difference between the price at which the bonds were sold and the repurchase price minus an allowance for the sum that had been charged off annually on account of the prorated discount on such bonds. — Treasury Decision 2137; also Art. 152, Reg. 33, Revised. Tf 644 — Losses — ^Previous. If for any taxable year beginning after October 31, 1918, and ending prior to January 1, 1920, it appears upon the production of evidence satisfactory to the Commissioner that any taxpayer has sustained a net loss, the amount of such net loss shall under regulations prescribed by the Com- missioner with the approval of the Secretary be deducted from the net income of the taxpayer for the preceding tax- able year ; and the taxes imposed by this title and by Title III. for such preceding taxable year shall be redetermined accordingly. Any amount found to be due to the taxpayer upon the basis of such redetermination shall be credited or refunded to the taxpayer in accordance with the provisions 383 CORPORATIONS— Cont^d DEDUCTIONS— Depreciation of section 252. If such net loss is in excess of the net in- come for such preceding taxable year, the amount of such excess shall under regulations prescribed by the Commis- sioner with the approval of the Secretary be allowed as a deduction in computing the net income for the succeeding taxable year. The benefit of this section shall be allowed to the members of a partnership and the beneficiaries of an estate of trust under regulations prescribed by the Commissioner with the approval of the Secretary. ^ 645 — Dividends Deductible. Amounts received as dividends from a corporation which is taxable under this title upon its net income, and amounts received as dividends from a personal service corporation out of earnings or profits upon which income tax has been imposed by Act of Congress. ^ 646— ' DEPRECIATION. A reasonable allowance for the depreciation of property used in the trade or business. Law, page 77, hne 3. 11 647 — Depreciation Deductible. A reasonable allowance for the exhaustion, wear and tear and obsolescence of property arising out of its use or employment in the business or trade during the taxable year shall be deducted from gross income. Depreciation as here used must be differentiated from depletion, and other losses elsewhere provided for. The deduction for depreciation should be the amount of the loss occurring during the year to which the return relates, estimated on the cost of the physical property with respect to which such deduction is claimed, which loss re- sults from wear and tear due to the use to which the prop- erty is put and which loss has not been made good through expenditures for renewals, replacements, and repairs, de- ducted under the heading of expense for maintenance and operation. 384 CORPORATIONS— Cont^d DEDUCTIONS— Depreciation ^ 648 — Rate for Computing. No definite rate has been fixed by which an allowable deduction on account of depreciation in the value of any class of property subject to wear and tear and obsolence is to be computed, but it is contemplated that this allowance shall be computed upon the basis of the cost of the property and the probable number of years constituting its life. The life of property necessarily depends upon its char- acter, the uses to which it is put, and the conditions under which it is used. These elements being taken into consid- eration, corporations should, as a result of experience and observation, very closely approximate the number of years constituting the life of the property and upon this basis determine the rate of depreciation which annually occurs. ^ 649 — Rate Based Upon Life of Buildings. In the case of buildings the deduction on account of de- preciation shall not include any allowance for an estimated loss due to lessening of rental value, nor shall the compu- tation of the deduction be influenced by the changed environment after a period of years, nor by its lack of adaptability to the use originally intended nor to any other outside influence affecting its value but an allowable de- preciation shall be determined solely upon the estimated life of such buildings after making due allowance for ordi- nary repairs, the cost of which may be deducted as expenses for maintenance and operation. — Art. 162, Reg. 33 ; Revised. If 650 — Assets Not Subject to Wear and Tear. Assets of any character whatever which are not afl^ected by use, wear, and tear (except patents, copyrights, etc.) are not subject to the depreciation allowance authorized by this Act. Real estate as such, and as distinct from the improve- ments thereon, is not reduced in value by reason of wear and tear, and it therefore follows that the "allowance" con- templated as an offset to depreciation in the case of real estate corporations does not apply to the ground, but is in- tended to measure the decline, by reason of wear and tear, in the value of the improvements. — Treasury Decision 2152 ; also Art. 162, Reg. 33 ; Revised. 385 CORPORATIONS— Cont^d DEDUCTIONS— Depreciation \] 651 — Buildings, Machinery, etc., Constructed for War Purposes. In the case of buildings, machinery, equipment, or other facilities, constructed, erected,, installed or acquired on or after April 6, 1917-, for the production of articles contrib- uting to the prosecution of the present war, and in the case of vessels constructed or acquired on or after such date for the transportation of articles or men contributing to the prosecution of the present war, there shall be allowed a reasonable deduction for the amortization of such part of the cost of such facilities or vessels as has been borne by the taxpayer, but not again including any amount other- wise allowed under this title or previous Acts of Congress as a deduction in computing net income. At any time with- in three years after the termination of the present war, the Commissioner may, and at the request of the taxpayer shall, re-examine the return, and if he then finds as a result of an appraisal or from other evidence that the deduction origi- nally allowed was incorrect, the taxes imposed by this title and by Title III. for the year or years affected shall be redetermined; and the amount of tax due upon such rede- termination, if any, shall be paid by the taxpayer upon notice and demand by the collector, or the amount of tax overpaid, if any, shall be credited or refunded to the tax- payer in accordance with the provisions of Section 252. If 652 — VaRie to Be Estimated — When. In determining the cost of the real estate upon which depreciable property is located it frequently occurs that no segregation is made of the cost of buildings as separate and distinct from the cost of the ground upon which such buildings stand. In such cases where the actual cost of the building or improvements at the time they were taken over by the corporation can not be definitely determined, it will be sufficient for the purpose of determining the rate of depreciation to be used in com- puting the amount which will be deductible from gross in- come to estimate the actual value at the time acquired, of buildings or improvements if acquired after March 1, 1913, CORPORATIONS— Cont'd DEDUCTIONS— Depreciation or the fair marketj price or value as of that date if the property was acquired prior to March 1, 1913, the value in either case to be reduced by the amount of depreciation previously sustained. — Treasury Decisions 2137 and 2152; also, Art. 163, Reg. 33; Revised. ti 653 — Diversion of Fund. If a corporation at the end of the year finds it has a certain net income, and, without making any provision for depreciation, distributes such net income among its stock- holders as dividends, it will be estopped from claiming in its returns of annual net income for such year any deduc- tion on account of depreciation unless it is shown conclu- sively that the property account has been reduced by the amount of depreciation claimed, or unless such amount has been credited to a depreciation reserve account, and such amount was in fact a reasonable allowance. The depreciation allowance is intended to provide a fund out of which the loss due to use, wear, and tear may be made good, and the fund thus created can not be diverted to the payment of dividends ; that is to say, a deduction made under the guise of depreciation can not measure a loss and at the same time be used in the payment of dividends. The fact that no reserve was made for depreciation indi- cates that there is no loss on this account to be provided for. —Art. 161, Reg. 33 ; Revised. U 654 — Use of Depreciation Reserve. Depreciation set up on the books and deducted from gross income can not be used for any purposes other than in making good the loss sustained by reason of the wear and tear of the property with respect to which it is claimed. If, however, an investment is made in extensions, addi- tions, or betterments of the company's own property, repre- senting a part or the whole of the credit balance of the depreciation reserve account, such investment will not be considered a misuse or diversion of the depreciation deduc- tion otherwise allowable. — Art. 164, Reg. 33 ; Revised. Investments in additions and extensions are primarily capital investments and the fact that the corporation is 387 CORPORATIONS— Cont'd DEDUCTIONS—Depreciation investing its depreciation funds in additions and better- ments or improvements would seem to indicate that the amounts set aside on account of depreciation were in excess of a reasonable allowance which the law contemplates a corporation may deduct from its gross income, and when it shall appear that by reason of the investing of its depre- ciation funds in additions, betterments, and improvements, it actually adds to the value of its capital assets it will be insisted upon that the amount by which the assets are in- creased on this account shall be returned as income and be subject to the income tax. [I 655 — Depreciation In Excess of Cost. If it develops that by reason of underestimating the life of the property or by overestimating the rate of deteriora- tion an amount in excess of the yearly depreciation has been taken, the rate applicable to future years should at once be reduced and the balance of the cost of the property not provided for through a depreciation reserve should be spread over the estimated remaining life of the property. — Art. 165, Reg. 33 ; Revised. ^ 656 — Reserves for Depreciation. Reserves for depreciation constitute proper deductions from gross income if reasonable, and not to be disallowed if converted into other forms of assets. ^ 657 — Depreciation Must Be Charged Off. Within the purview of this item depreciation, to an amount measuring the decline in value due to exhaustion, wear and tear of property arising out of its use, is a loss. This loss, in order to constitute an allowable deduction from gross income, must be charged off. The particular manner in which the amount shall be charged off is not material, except that the amount measuring a reasonable allowance for depreciation must be either deducted directly from the book value of the assets or credited to a depreciation reserve account, and as such shall be reflected in the annual balance sheet. (See Sec. 1001, Act of Oct. 3, 1917.) —Art. 159, Reg. 33 ; Revised. 388 CORPORATIONS— Cont'd DEDUCTIONS— Depreciation U 658 — Shrinkage in Book Values. Depreciation in book values of capital assets shall be treated in the return in the manner prescribed in the case of loss from the sale of capital assets (U 575), but amounts arbitrarily charged off will not be allowed as deductions except so far as they represent an actual shrinkage in values which may be determined to have taken place during the year for which the return is made. Book values which reflect a shrinkage in value of assets are not a basis for determining taxable income. — Treasury Decision 2090. ^ 659 — Depreciation in Value of Stocks and Bonds. Depreciation allowed by law does not include shrinkage in value of stocks and bonds. ^ 660 — Shrinkage in Securities. A corporation possessing securities, such as stocks and bonds, can not allowably deduct from gross income any amount claimed as a loss on account of the shrinkage in value of such securities through fluctuations of the market or otherwise; the only loss to be allowed in such cases is that actually suffered when the securities mature or are disposed of. In the case of banks or other corporations which are subject to supervision by State or Federal authorities, and which, in obedience to the orders of such supervisory of- ficers, charge off as losses, amounts representing an alleged shrinkage in the value of property, real, personal, or mixed, the amounts so charged off do not constitute allowable de- ductions. Deductible losses are those only which are de- termined upon the basis of a closed or completed transac- tion.— Treasury Decisions, 2005, 2130 and 2152. The fore- going applies only to owners and investors and not to dealers in securities, as to which see Treasury Decision 2609, Art. 148, Reg. 33; Revised. TI 661 — Irrigation Bonds — Losses on. District irrigation bonds generally are a lien upon the real estate affected by the irrigation project, and until a corporation holding such bonds has taken the necessary 389 CORPORATIONS— Cont'd DEDUCTIONS— Depreciation action to protect its interest and enforce the collection of the bonds the corporation will not be allowed to deduct from gross income, as a loss, the face value or any estimated amount supposed to represent a loss or shrinkage in the value of such bonds. Any estimated shrinkage in the value of bonds or other securities does not constitute a loss with- in the meaning of this title. So long as the value of a se- curity is uncertain or unknown a loss can not be definitely ascertained and is therefore not deductible. — Treasury De- cisions 2005, 2130 and 2152. H 662— Discount on Bonds Issued Prior to 1909. Discount on bonds issued and sold prior to the year 1909, if such discount was then charged against surplus or against the income of the year in which the bonds were sold, is held not to be deductible from! the income of subsequent years, for the reason that the charging off prior to January 1, 1909, of the entire amount of the discount constitutes a closed transaction, and such transaction can not be reopened for the purpose of reducing the taxable income of a cor- poration for subsequent years by deducting therefrom an aliquot part of the discount. (C. & A. R. R. v. U. S., Court of Claims.)— Art. 149, Reg. 33, Revised. f[ 663 — Bond Discount and Expense to Be Amortized. If, however, the bonds were sold subsequent to January 1, 1909, at a discount, and the amount of the discount was then charged off on the books, either against earnings or surplus, but not deducted in the corporation's return of net income, such discount as was not then deducted in its entirety, may be spread over the life of the bonds, and an ahquot part of the discount may be deducted from the gross income of each year until the bonds mature or are re- deemed. In cases wherein a corporation sells its bonds at a dis- count plus a commission for selling, the amount of such dis- count and commission, together with other expenses inci- dental to issuing the bonds, constitute a loss, the aggregate 390 CORPORATIONS— Cont'd DEDUCTIONS—Depreciation amount of which loss will, for thfe purpose of an income tax return, be prorated over the life of the bonds sold, and the amount thus apportioned to each year will be deductible from the gross income of each such year until the bonds shall have been redeemed. If a corporation having sold its bonds at a discount, the discount having been deducted from gross income later re- purchases or redeems the bonds at a price less than par, the difference between the price at which they are redeemed and their par value will be returned as income. If bonds are sold at a premium the premium must be returned as in- come. — Art. 150, Reg. 33, Revised. ^ 6e4--Good Will. "Good will" represents the value attached to a business over and above the value of the physical property, and is such an intangible asset that it is not subject to wear and tear, and no claim for depreciation in connection therewith can be allowed. Any loss resulting from or on account of an investment in "good will" can be determined only when the property or business to which the good will attaches is sold or disposed of, in which case the profit or loss will be de- termined upon the basis of the value of the assets includ- ing good will if acquired prior to March 1, 1913, or their cost if acquired subsequent to that date. — Art. 167, Reg. 33, Revised. ^ 665 — No Deduction for Depreciation of Good Will, Trade-marks, and Trade Brands. No deduction will be allowed for the depreciation of good will, trade-marks, and trade brands. If such assets shall have been purchased at a determined price and shall be later sold at a price less than such cost, or less than their determined fair market value as of March 1, 1913, if acquired prior to that date, the amount by which the selling price is less than the cost or value, as the case may be, will be a loss de- ductible from the gross income of the year in which such assets were sold. — Art. 168, Reg. 33, Revised. 391 CORPORATIONS— Cont'd DEDUCTIONS— Depreciation U eee — Patents, Deduction for Return of Capital Invested Therein. An allowable deduction for any given year for return of capital invested in patents at time of issue will be an amount equal to one-seventeenth of the actual cost, in cash or its equivalent, of such patents. Where the patent has been secured from the Government, its cost will be rep- resented by the various Government fees, cost of drawings, experimental models, attorneys' fees, etc., actually paid. Where the patent has been purchased for a cash considera- tion, the amount paid therefor would represent the capital invested therein. If the corporation purchased a patent and made payment therefor in stock or other securities, the ac- tual cash value of such stocks or other securities at the time of the purchase will represent the cost or capital invested in the patent. If the patent was purchased after a part of its life had expired, the cost for the purpose of a deduction for return of capital will be ratably spread over the remaining years of its life. If the patent becomes obsolete prior to its expiration, it will be permissible for the corporation to deduct from gross income such proportion of its original cost (less any amount previously charged off) as the num- ber of years of its remaining life bears to the whole number of years intervening between the date it was acquired and the date it legally expires. In determining the amount de- ductible on account of the expiring life of patents only the actual cost thereof and not an estimated value as of March 1, 1913, or any other date, will be considered. — Art. 174, Reg. 33, Revised. Ij 667 — Cost of Successful Drawing, Models, Etc., Capital. When a corporation has made expenditures for designs, drawings, patterns or models representing work of an ex- perimental nature, and such designs, drawings, patterns, or models prove to be satisfactory and result in the produc- tion of salable goods, they will be treated as a capital asset, and the entire cost thereof, including experimental and de- velopment expenses, will be capitalized, in which case no part of such expenditures shall be included in expenses of run- 392 CORPORATIONS— Cont'd DEDUCTIONS— Depreciation ning the business and shall not be treated as a deduction from gross income. — Art. 175, Reg. 33, Revised. ^ 868 — Cost of Unsatisfactory Models, Drawings, Etc., a Loss. If, however, the designs, drawings, patterns, or models prove by actual experience to be unsatisfactory and do not result in the production of salable goods and have no asset value, such expenditures when charged off may be included as a loss incident to running the business and as such deducted from gross income, provided that the corporation in taking credit for such expenditures in its income tax re- turn shall make a full and complete explanation with respect to the same and to the satisfaction of the Commissioner of Internal Revenue. — Art. 176, Reg. 33, Revised. ^ 660 — Obsolescence of Models, Drawings, Etc., as a Loss. If designs, drawings, patterns, or models result in the pro- duction of goods which prove to be salable for a certain length of time and then become obsolete and can not be sold, the amount expended for such designs, drawings, patterns, or models, less any amounts previously claimed as deprecia- tion with respect to the same or as a return of capital, may when charged oif , be included in, and deducted as a loss in- cident to running the business, provided full and complete information is reported in a manner satisfactory to the Com- missioner of Internal Revenue. — Art. 177, Reg. 33, Revised. ^ 67© — Obsolescence Deductible, Cost Less Depreciation and Salvage. Amounts representing losses on account of obsolescence of physical property may be included as a deduction from gross income as a loss, provided such amounts have been recorded in the books following the condemnation and withdrawal from use of the obsolete property. The amount of obsoles- cence that may be claimed as a deduction shall be ascer- tained by deducting from the cost of the property the total amount that has been previously claimed and deducted on account of the depreciation of the property, plus residual value at time of obsolescence, or plus the amount received 393 CORPORATIONS— Cont^d DEDUCTIONS— Depreciation from the sale of the property. The obsolescence deduction must not include the accumulated depreciation applicable to prior years. — Art. 178, Reg. 33, Revised. K 671 — Obsolescence When No Depreciation is Deducted. If no depreciation has been charged off against such prop- erty and deducted from gross income of prior years, the amount allowable as a deduction for the year in which the property becomes obsolete shall be ascertained by deducting from the cost of the property its residual value plus an amount equal to the depreciation actually sustained during the prior period and which might have been deducted when computed at the rate applicable to the same or similar prop- erty. The amount of depreciation thus arrived at as ap- plicable to former years may be made the basis of amended returns and a claim for the refund of taxes overpaid by reason of the fact that no depreciation deduction was claimed in those years. — Art. 179, Reg. 33, Revised. H 672— Sale of Patents. A corporation disposing of patents by sale should deter- mine the profit or loss arising therefrom by computing the difference between the selling price and the value as of March 1, 1913, if acquired prior to that date, or between the selling price and the cost, if acquired subsequent to that date. The profit or loss thus ascertained should be increased or decreased, as the case may be, by the amounts deducted on account of depreciation of such patents since March 1, 1913, or since the date or purchase if acquired subsequent to that date. — Art. 157, Reg. 33, Revised. ^ 673 — Rules far Timber-owning Lumber Companies. Corporations owning timber land and logging off the tim- ber and manufacturing it into lumber, will, if the timber is acquired prior to March 1, 1913, be permitted to exclude from gross income either through a deduction from gross re- ceipts or through a charge into the cost of manufacturing the timber into lumber, an amount equivalent to the fair market price or value of the standing timber as of March 1, 1913. 394 CORPORATIONS— Cont'd DEDUCTIONS— Depreciation In order to secure the benefit of this deduction such cor- porations must set up on their books as of March 1, 1913, the fair market price en bloc, of all the timber then owned by them, and then, by dividing his en bloc value by the esti- mated number of feet (board measure) in the entire timber holdings, the per unit value or price as of March 1, 1913, will be ascertained, which per unit price or value will be the basis for measuring the amount which may be added to the cost of manufacture, or deducted from gross income, until the en bloc value of the entire holding as of March 1, 1913, shall have been extinguished, after which no further deduc- tion on this account shall be allowed. The same rule will apply in the case of timber or timber lands, purchased subsequent to March 1, 1913, the only dif- ference being that actual cost — that is, the gross purchase price — shall, in making the computation, be substituted for en bloc price or value as of that date. If the entire market price or value of both timber and lands as of March 1, 1913, or the entire cost, if acquired subsequent to that date, is extinguished through a deduction from gross income for timber used, or through a per unit charge to cost of manu- facturing lumber, then the entire amount realized from the logged-off lands or for other salvage will be returned as in- come of the year in which such lands are sold or disposed of. ""if the timber or timber lands are sold en bloc, the gain or loss will be ascertained on the basis of the difference be- tween the fair-market price, or cost, and the selling price, according as the property was acquired prior or subsequent to March 1, 1913. The fair market price or value of timber or timber lands as of March 1, 1913, is the price at which the property in its then condition, and with the circumstances then surrounding it, could have been sold for cash or its equivalent. This value must not be speculative, but must be determined without taking into account any prospective profits that may result from the manufacture of the timber into lumber. It must be, as the law contemplates, a fair market value and, once determined, must be set up on the books and, as the measure of a stumpage deduction for income-tax purposes, must re- 395 CORPORATIONS— Cont'd DEDUCTIONS— Depreciation main constant and can not be increased except as new pur- chases are made at a higher average cost. The value so set up as of March 1, 1913, will be subject to the approval of the Commissioner of Internal Revenue. — Art. 173, Reg. 33, Re- vised. II 674 — Court Decision Relative to Depreciation of Property. Under a decision of the United States District Court, Western District of Michigan, Southern District, there may- be deducted on account of depreciation, the difference be- tween the original cost price of property and its increased fair market value at the time of the incidence of the Special Excise Tax of 1909. A lumber company in 1913 had paid certain amounts for standing merchantable hardwood tim- ber, pine timber and cut-over stump land, carrying the prop- erty so acquired on its books at cost price. In its excise tax returns for 1909 to 1912, inclusive, the company deducted from gross receipts from sales of timber and stump lands, for return to capital assets, an amount representing the dif- ference in original cost and what was admitted to be a fair market value at the time of the incidence of the special ex- cise tax of 1909. The Government allowed the original cost as a deduction, but assessed an additional tax on the increase of value deducted by the company. The company sued to recover the additional tax paid under protest and received judgment for the amount of excess taxes so paid. ^ 675 — Depreciation of Improvements. In addition to the deduction to measure the loss due to de- pletion, a corporation will be allowed depreciation on im- provements at mines, oil and gas wells and all other natural deposits in accordance with the peculiar conditions in each case and based on life and cost. ^ 676 — Corporations Leasing Oil or Gas Territories. Corporations leasing oil or gas territory shall base their depletion deduction in accordance with paragraph 677, which shall be equitably apportioned between the lessor and the lessee. 396 CORPORATIONS— Cont'd DEDUCTIONS— Interest ^ 677— Depletion— Mines, Oil and Gas Wells, Other Natural Deposits and Timber. In the case of mines, oil and gas wells, other natural de- posits, and timber, a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar conditions in each case, based upon cost including cost of de- velopment not otherwise deducted. In the case of such properties acquired prior to March 1, 1913, the fair market value of the property (or the taxpayer's interest therein) on that date shall be taken in lieu of cost up to that date. In the case of mines, oil and gas wells, discovered by the tax- payer, on or after March 1, 1913, and not acquired as the re- sult of purchase of a proven tract or lease, where the fair market value of the property is materially disproportionate to the cost, the depletion allowance shall be based upon the fair market value of the property at the date of the dis- covery, or within 12 months thereafter. Such reasonable allowance in all the above cases to be made under rules and regulations to be prescribed by the Commissioner with the approval of the Secretary. In the case of leases, the deduc- tions allowed by this paragraph shall be equitably appor- tioned between the lessor and lessee. INTEREST. 1[ 678 — What Constitutes Allowable Interest Deduction. All interest paid or accrued within the taxable year on its indebtedness, except on indebtedness incurred or continued to purchase or carry obligations or securities (other than obligations of the United States issued after September 24, 1917) the interest upon which is wholly exempt from taxa- tion under this title as income to the taxpayer. If a corporation borrows money to purchase securities the interest from which is not subject to the corporation income tax, the interest paid on such borrowed money cannot be used as a deduction. See also H 679. ^ 679 — Interest on Indebtedness as Rental. Interest paid pursuant to contract on an indebtedness se- cured by mortgage on real estate occupied and used by a 397 CORPORATIONS— Cont'd DEDUCTIONS— Taxes corporation, in which real estate the corporation has no equity or to which it is not taking title, is an allowable de- duction from gross income as a rental charge, payment of which is required to be made as a condition to the continued use and possession of the property. If, however, the cor- poration has an equity in or is purchasing for its own use the real estate upon which such mortgage is a prior lien, the in- debtedness will be held to be indebtedness of the corporation within the meaning of the law and the interest paid on such mortgage will be deductible only to the extent that, includ- ing interest on other obligations of the corporation, it is within the limit fixed by the law. — Treasury Decisions 2090 and 1993 ; also. Art. 186, Reg. 33 ; Revised. |[ 680 — Interest on Deposits. In the case of banks and banking associations, loan or trust companies, interest paid within the year on deposits or on moneys received for investment and secured by inter- est-bearing certificates of indebtedness issued by such bank, banking association, loan or trust company, may be allow- ably deducted from the gross income of such corporation. — Art. 190, Reg. 33 ; Revised. ^ 681 — Different Rates of Interest on Indebtedness. Interest on bonded or other indebtedness bearing differ- ent rates of interest may be deducted from gross income during the year. fl 682 — Interest Paid by Brokerage Corporation. Interest paid by a brokerage corporation on part pur- chases of securities for its customers is allowable as interest payable on its bonded or other indebtedness. ^ 683— TAXES. Taxes paid or accrued within the taxable year imposed (a) by the authority of the United States, except income, war-profits and excess-profits taxes ; or (b) by the authority of any of its possessions, except the amount of income, war profits and excess profits taxes allowed as a credit under Section 238 ; or (c) by the authority of any State or Ter- 398 CORPORATIONS— Cont'd DEDUCTIONS— Taxes ritory, or any county, school district, municipality, or other taxing subdivision of any State or Territory, not including those assessed against local benefits of a kind tending to increase the value of the property assessed; or (d) in the case of a domestic corporation, by the authority of any foreign country, except the amount of income, war profits and excess profits taxes allowed as a credit under Section 238 (income, war profits and excess-profits taxes paid to a foreign country) ; or (e) in the case of a foreign corpora- tion, by the authority of any foreign country (except in- come, war profits and excess profits taxes, and taxes as- sessed against local benefits of a kind tending to increase the value of the property assessed), upon the property or business : Provided, That in the case of obligors specified in subdivision (b) of Section 221, no deduction for the payment of the tax imposed by this title or any other tax paid pur- suant to the contract or provision referred to in that sub- division, shall be allowed. H 684— -Tax-Free Bonds. In the case of bonds or other forms of indebtedness issued with a guaranty that the interest thereon shall be free from taxation as against the holder the corporation paying the tax pursuant to its guaranty, whether Federal, State, or mu- nicipal, will not be permitted to deduct the tax so paid. The tax assessable upon this income is a direct liability of the recipient, and the debtor corporation paying it does so vol- untarily or at least in pursuance of a contract voluntarily entered into, which contract is in nowise binding upon or to be recognized by the Government in determining the tax liability of the corporation. Hence taxes so paid are not deductible from the gross income of the debtor. — ^Treasury Decision 2161 ; also. Art. 193, Reg. 33 ; Revised. 1| 685— Local Benefits. So-called "taxes," more properly assessments, paid for local benefits, such as street, sidewalk and other like assess- ments, imposed because of and measured by some benefit inuring directly to the property against which the assess- ment is levied, do not constitute an allowable deduction from 399 CORPORATIONS— Cont'd DEDUCTIONS— Taxes gross income. Taxes deductible are those levied for the public welfare by the proper taxing authorities at a like rate against all property in the territory over which such authorities have jurisdiction. Special assessments, such as are hereinbefore contem- plated and which are measured upon the basis of the benefit flowing directly to the property, are not deductible, even though an incidental benefit may inure to the public wel- fare.— Treasury Decision 2090; also, Art. 194, Reg. 33; Revised. '"'"^W^ ^ 686— Excess Profits Tax as a Credit. That in assessing income tax the net income embraced in the return shall also be credited with the amount of any war-excess profits tax imposed by Title III. of the Revenue Act of 1918, and assessed for the same calendar or fiscal year upon the taxpayer. ^ 687— Bank Stock Taxes Paid for Shareholders. Banks paying taxes assessed against their stockholders on account of their ownership of the shares of stock issued by such banks can not deduct the amount of taxes so paid in making their returns for the purpose of the income tax imposed by this title unless and to the extent that the laws of the State in which they do business by specific terms make the tax a direct liability of such banks that is a lien upon its property. The shares of stock are the property of the stockholders, and to the extent that the taxes as- sessed on the value of the shares of stock are property taxes the holders are primarily liable for their payment. The fact that State laws make it the duty of banks to pay the tax does not necessarily make the tax a liabihty of the banks. These provisions of State laws are intended only to provide a convenient means whereby the tax assessed against the stock on the basis of its value can be the more readily collected by the tax-collecting officers and do not attempt to assert liability against the bank, as is evidenced by the fact that in most, if not all, cases, the tax is a lien upon the stock. For this purpose the Hability of the bank is limited to the duty to collect or withhold from the stock- 400 CORPORATIONS— Cont^d DEDUCTIONS— Taxes holders the amount of taxes due and to pay the same over to the proper tax-collecting offices. Federal statutes pro- hibit States from imposing any tax upon national banks except upon the value of their real estate. In cases where States levy a tax on the stock of such banks and make it the duty of the banks to pay such tax for the stockholders, said payments are not deductible from the gross income of such banks. — Treasury Decisions 2121, 2152. This rule applies only to taxes levied upon the value of the capital stock, and it is not intended to so operate as to prevent banking corporations from deducting from their gross income any State tax imposed against the corporation itself on the value of its real estate, furniture and fixtures, or as an excise or a franchise tax ; that is, a tax which the corporation is required to pay to the State on account of its own property or business in order that it may transact busi- ness within the State is deductible. — ^Treasury Decisions 2153, 2121. This rule hereinbefore set out will apply in the case of corporations other than banks, upon the value of whose stock taxes are assessed to the stockholders. — Art. 192, Reg. 33 ; Revised. ^ 688 — Customs Duties Deductible as Expenses — ^Not Taxes. Import duties or taxes are not deductible under the item of taxes paid during the year, but should be included in arriving at the cost of goods under item (expenses) . [In private letters the Department has held that customs duties are deductible by an individual as taxes, or part of the cost price if the indi- vidual is engaged in the importation of goods and merchandise. — Ed.] If 689— Import or Tariff Duties. Import or tariff duties levied by the act of Congress and paid to the proper customs officers, stamp taxes, and all other taxes (except income and excess profits taxes) im- posed by internal-revenue laws and paid to collectors are deductible as taxes imposed under authority of the United States, provided they are not added to and made a part of the cost of articles of merchandise with respect to which 401 CORPORATIONS— Continued CREDITS they are paid, in which case they will be reflected in the cost of merchandise and can not be separately deducted. — Art. 195, Reg. 33 ; Revised. ^ 690— Credits Allowed. That for the purpose only of the tax imposed by section 230 (which is the tax on net incomes of corporations) there shall be allowed the following credits: (a) The amount received as interest upon obligations of the United States and bonds issued by the War Finance Corporation which is included in gross income. (b) The amount of any taxes imposed by Title III of the-Revenue Act of 1918 for the same taxable year. In the case of a corporation which makes return for a fiscal year beginning in 1917 and ending in 1918, in computing the tax as provided in subdivision (a) of Section 275 (tax based on fiscal year beginning in 1917 and ending in 1918), the tax computed for the entire period under Title II. of the Revenue Act of 1917 (excess-profits tax), shall be credited against the net income computed for the entire period under Title I. of the Revenue Act of 1916 as amended by the Revenue Act of 1917 and under Title I. of the Revenue Act of 1917 (In- come Tax), and the tax computed for the entire period under the war-profits and excess-profits title of the Revenue Act of 1918 at the rates prescribed for the calendar year 1918 shall be credited against the net income computed for the entire period under the income tax title of the Revenue Act of 1918. (c) In the case of a domestic corporation $2,000.. The following example shows how these credits should be treated in a return of annual net income : A corporation with a net income of $100,000 — for the cal- endar year 1918. Included in gross income is interest to the extent of $5,000 from Liberty Bonds and bonds of the War Finance Corporation. 402 CORPORATIONS— Continued GENERAL The amount of the War Excess Profits tax is $45,000. Net income $100,000 Credits : Interest on Liberty Bonds and bonds of the War Finance Corporation $5,000 War excess-profits tax 45,000 Additional credit 2,000 Total credits 52,000 Taxable income $48,000 Corporation income tax ($48,000 at 12%) $5,760 Excess-profits tax 45,000 Total tax $50,760 ^ 691 — Foreign Corporations Subject to Tax. Foreign corporations are subject to the normal tax of 12 per cent, upon the total net income received in the pre- ceding calendar or fiscal year from all sources within the United States. Such income includes interest on bonds, notes, or other interest-bearing obligations of residents, cor- porate or otherwise, and also the income derived from divi- dends on capital stock or from the net earnings of resident corporations, etc., whose net income is taxable under the law, and including all amounts received (although paid under a contract for the sale of goods or otherwise) repre- senting profits on the manufacture and disposition of goods within the United States. While the dividends received must be included in gross income they are not subject to the tax, being deducted from gross income in arriving at the net income subject to tax. ^ 692 — Returns of Domestic Corporations Whose Books Are Kept in Foreign Countries — Where Filed. See "Place of Filing Returns," TI 507. 403 CORPORATIONS— Continued GENERAL jf 693 — Deductions From Income Allowed. Such net income shall be ascertained by deducting from the gross amount of its income received within the year from all sources within the United States — jl 694 — Expenses Within United States. All the ordinary and necessary expenses paid or incurred within the taxable year to the extent that they are con- nected with income arising from a source within the United States, including a reasonable allowance for salaries or other compensation for personal services actually rendered, and including rentals or other payments required to be made as a condition to the continued use or possession of property to which the corporation has not taken or is not taking title, or in which it has no equity. The proper apportionment and allocation of the deduc- tions under this caption with respect to sources of income within the United States shall be determined under rules and regulations prescribed by the Commissioner of Internal Revenue. U 695 — Interest on Indebtedness. The proportion of interest paid or accrued within the taxable year on its indebtedness, which the amount of its gross income from sources within the United States bears to the amount of its gross income from all sources within and without the United States, except on indebtedness incurred or continued to purchase or carry obligations or securities (other than obligations of the United States issued after September 24, 1917) the interest upon which is wholly ex- empt from taxation under this title as income to the tax- payer. ^ 696 — Source Within United States. It is not necessary that the foreign corporation shall be engaged in business in this country or that it have an office, branch, or agency in the United States. Liability to the tax attaches with respect to the income, the source of which is in the United States. "Source" as here used means the place of origin of the income. 404 CORPORATIONS— Continued GENERAL ^697— Taxes. In the case of a foreign corporation, by the authority of any foreign country (except income, war-profits and excess- profits taxes, and taxes assessed against local benefits of a kind tending to increase the value of the property assessed) , upon the property or business. That in the case of obligors specified in subdivision (b) of section 221 (Payment of Tax at Source) no deduction for the payment of tax imposed by this title or any other tax paid pursuant to the contract or provision referred to in that subdivision shall be allowed. H 698 — Bonds Issued With Tax-Free Covenant Clause — Interest From, Not Deductible. In the case of bonds or other indebtedness which have been issued with a guaranty that the interest payable there- on shall be free from taxation, no deduction for the pay- ment of the tax herein imposed or any other tax paid pursuant to such guaranty shall be allowed. jf 699— -Losses. Losses sustained during the taxable year and not com- pensated for by insurance or otherwise are deductible. For apportionment and allocation, see 1[ 694. 11 700— -Debts. Debts ascertained to be worthless and charged off within the taxable year are deductible. For apportionment and allocation, see jf 694. 11701— -Dividends. Amounts received as dividends from a corporation which is taxable under this title upon its net income, and amounts received as dividends from a personal service corporation out of earnings or profits upon which income tax has been im- posed by Act of Congress are deductible. 1[ 702 — Depreciation. A reasonable allowance for the depreciation of property used in the trade or business. For apportionment and allo- cation, see K 694. 405 CORPORATIONS— Continued GENERAL II 703 — No Deductions for New Buildings, Permanent Improvements, Betterments, Etc. Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate shall not be allowed as a deduction. li 704 — Restoration of Property. Any amount expended in restoring property or in making good the exhaustion thereof for which an allowance is or has been made is not deductible. |[ 705 — Amortization. In the case of buildings, machinery, equipment, or other facilities, constructed, erected, installed, or acquired, on or after April 6, 1917, for the production of articles contrib- uting to the prosecution of the present war, and in the case of vessels constructed or acquired on or after such date for the transportation of articles or men contributing to the prosecution of the present war, there shall be allowed a reasonable deduction for the amortization of such part of the cost of such facilities or vessels as has been borne by the taxpayer, but not again including any amount other- wise allowed under this title or previous Acts of Congress as a deduction in computing net income. At any time within three years after the termination of the present war, the Commissioner may, and at the request of the taxpayer shall, reexamine the return, and if he then finds as a result of an appraisal or from other evidence that the deduction originally allowed was incorrect, the taxes imposed by this title and by Title III. for the year or years affected shall be redetermined ; and the amount of tax due upon such re- determination, if any, shall be paid upon notice and demand by the collector, or the amount of tax overpaid, if any, shall be credited or refunded to the taxpayer in accordance with the provisions of Section 252. ^ 706 — Depletion and Depreciation. In the case of mines, oil and gas wells, other natural de- posits, and timber, a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar 406 CORPORATIONS— Continued GENERAL conditions in each case, based upon cost including cost of development not otherwise deducted. In the case of such properties acquired prior to March 1, 1913, the fair market value of the property (or the taxpayer's interest therein) on that date shall be taken in lieu of cost up to that date. In the case of mines, oil and gas wells, discovered by the taxpayer, on or after March 1, 1913, and not acquired as the result of purchase of a proven tract or lease, where the fair market value of the property is materially disproportionate to the cost, the depletion allowance shall be based upon the fair market value of the property at the date of the dis- covery, or within 30 days thereafter ; such reasonable allow- ance in all the above cases to be made under rules and regulations to be prescribed by the Commissioner with the approval of the Secretary. In the case of leases the de- ductions allowed by this paragraph shall be equitably ap- portioned between the lessor and lessee; If 707 — How Deductions Shall Be Evidenced. It is immaterial whether the deductions are evidenced by actual disbursements in cash, or whether evidenced in such other way as to be properly acknowledged by the corporate officers and so entered on the books of the corporation as to constitute a liability against the assets of the corporation making the return. Deductions for taxes should be the aggregate of the amounts actually paid or accrued within the taxable year, as shown on the books of the corporation. ^ 708— Tax Withheld at Source. In making its return a foreign corporation may take credit against the tax assessable on the basis of the net income so returned for any tax which may have been with- held at the source, provided the income upon which the tax was withheld is included in the return and provided that the name of the withholding agent is given in the return. —Art. 198, Reg. 33, Revised. Deductions for losses should be confined to losses sus- tained during the taxable year and not compensated by in- surance or otherwise. 407 CORPORATIONS— Continued RETURNS Except as the same may be modified by the provisions of the Act, limiting certain deductions and authorizing others, the net income as returned for the purpose of the tax should be the same as that shown by the books or the annual balance sheet. ]\ 70d — Inventories. That whenever in the opinion of the Commissioner of Internal Revenue the use of inventories is necessary in order clearly to determine the income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the Commissioner may prescribe as conforming as nearly as may be to the best accounting practice in the trade or busi- ness and as most clearly reflecting the income. RETURNS. If 710 — Forms of Returns. Four separate revised forms of annual return have been provided for corporations as follows: Corporations. Form (For all corporations except railroad and in- surance companies) 1031 (Revised) Insurance Companies. (Including mutual life and mutual marine) 1030 (Revised) Mutual Insurance Companies. (Other than mutual life and mutual marine) 1030 A Railroad Corporations. (Railroad corporations) 1090 TJ 711 — Consolidated Returns. That corporations which are affiliated within the meaning of this Section shall, under regulations to be prescribed by the Commissioner, with the approval of the Secretary, make a consolidated return of net income and invested capital for the purposes of this title and Title III., and the taxes there- under shall be computed and determined upon the basis of such return : Provided, That there shall be taken out of such 408 CORPORATIONS— Continued RETURNS consolidated net income and invested capital, the net income and invested capital of any such affiliated corporation or- ganized after August 1, 1914, and not successor to a then existing business, 50 per centum or more of whose gross income consists of gains, profits, commissions, or other in- come, derived from a Government contract or contracts made between April 6, 1917, and November 11, 1918, both dates inclusive. In such case the corporation so taken out shall be separately assessed on the basis of its own invested capital and net income and the remainder of such affiliated group shall be assessed on the basis of the remaining con- solidated invested capital and net income. In any case in which a tax is assessed upon the basis of a consolidated return, the total tax shall be computed in the first instance as a unit and shall then be assessed upon the respective affiliated corporations in such proportions as may be agreed upon among them, or, in the absence of any such agreement, then on the basis of the net income prop- erly assignable to each. There shall be allowed in comput- ing the income tax only one specific credit of $2,000 (as provided in Section 236) ; in computing the war-profits credit (as provided in Section 311) only one specific exemp- tion of $3,000 ; and in computing the excess-profits credit (as provided in Section 312) only one specific exemption of $3,000. For the purpose of this Section two or more domestic corporations shall be deemed to be affiliated (1) if one cor- poration owns directly or controls through closely affiliated interests or by a nominee or nominees substantially all the stock of the other or others, or (2) if substantially all the stock of two or more corporations is owned or controlled by the same interests. For the purposes of Section 238 a domestic corporation which owns a majority of the voting stock of a foreign cor- poration shall be deemed to have paid the same proportion of any income, war-profits and excess-profits taxes paid (but not including taxes accrued) by such foreign corpora- tion during the taxable year to any foreign country or to any possession of the United States upon income derived from sources without the United States, which the amount 409 CORPORATIONS— Continued RETURNS of any dividends (not deductible under Section 234) re- ceived by such domestic corporation from such foreign cor- poration during the taxable year bears to the total taxable income of such foreign corporation upon or with respect to which such taxes were paid : Provided, That in no such case shall the amount of the credit for such taxes exceed the amount of such dividends (not deductible under Section 234) received by such domestic corporation during the tax- able year. ^ 712 — Forms to Be Furnished. Under the authority conferred by this title, forms of re- turn have been prescribed in which the various items speci- fied in the law are to be stated. Blank forms of this return will be forwarded to collectors and should be furnished to every corporation, not expressly exempted, on or before January 1 of each year, in the case of corporations making their next returns for the calendar year; on or before the first day of the next fiscal year in the case of corporations filing returns for their fiscal year. Failure on the part of any corporation, joint-stock company, association, or insurance company liable to this tax to receive a prescribed blank form will not excuse it from making the return required by law or relieve it from any penalties for failure to make the return within the prescribed time. Tf 71 3 — Failure to Receive Returns. Corporations not supphed with the proper forms for mak- ing the return should make application therefor to the col- lector of internal revenue in whose district are located their principal places of business* in ample time to have their re- turns prepared, verified, and filed with the collector on or before the last due date defined by the law and these regula- tions. '•■The Principal of Business of a Corporation is the pince or office in which are kept the books of account and other data from which the return is to be prepared. — Treasury Decision 2090. ^ 714— Twenty-five Per Cent. Additional Tax. Failure in this respect subjects the corporation to not only 25 per cent additional tax, but to the specific penalty im- posed by the law for deHnquency. Each corporation should 410 CORPORATIONS— Continued RETURNS carefully prepare its return so as to fully and clearly set forth the data therein called for. Imperfect or incorrect returns will not be accepted as meeting the requirements of the law.— Art. 216, Reg. 33, Revised. If 715 — Itemized Statement on Form 1031. In the case of public-service and all other corporations it is desired that the supplementary statement which forms a part of the Return Form 1031, prescribed by the Secretary of the Treasury for the use of such corporations in making the returns of annual net income, shall be prepared as far as practicable in detail. It is not expected or required, however, that every par- ticular item going to make up either gross income or the de- ductions therefrom shall be set out in the supplementary statement. It will be sufficient in the case of public-service corporations and other similar concerns that they supply the information by classes rather than giving the items in de- tail, classifying the income and expenditures in the same manner as is required as to these items by the Interstate Commerce Commission. Ti 71 6 — Instructions to Corporations With Respect to Making Returns of Annual Net Income. The officers of corporations should read carefully the fol- lowing instructions, as well as those given on the Return Form (1031), before inserting the figures in either the re- turn proper or the supplementary statement. Returns must be filed by all corporations, not specifically enumerated as exempt, having existence during all or any part of the year, and, if made on the basis of a calendar year, must be filed on or before March 15 ; if on the basis of a fiscal, other than the calendar, year they must be filed on or before the fifteenth day of the third month next following the close of the fiscal year. Dissolved corporations, making returns on the basis of a calendar year, will make final return covering the period from January 1 to date of dissolution. Dissolved corpora- tions making return on the basis of a fiscal, other than the calendar, year will make a final return covering the period 411 CORPORATIONS— Continued RETURNS from the beginning of the fiscal year to the date of disso- lution. Date of dissolution in either case must be noted on the face of the return in red ink. New corporations, organized during the year, must make return covering the period from date of organization to De- cember 31, unless the Collector is given written notice, not less than 30 days prior to March 15, designating the last day of some month, other than December, as the closing date of the fiscal year. In this event a return will be made on or before the fifteenth day of the third month after the close of the fiscal year designated, provided the period from date of organization to the closing date of the fiscal year does not exceed 12 months. Further instructions will be given by the collector. Address in the heading must show where books are kept from which return is prepared, and the return will be filed in the district in which this address shows the books to be kept. ^ 717 — In the Absence of Notice, Fiscal Year Returns Not Acceptable. A return made on the basis of a fiscal year other than the calendar year can not be accepted unless such fiscal year shall have been established by proper notice to the Collector of Internal Revenue of the district in which such corpora- tion has its principal place of business (Treasury Decision 2090, 2152, 2137), and if in the absence of such notice and designation a return is filed subsequent to the date when it was required to be filed if made on a calendar-year basis, it will be considered delinquent and the corporation will be liable to the penalty imposed for failure to file the return within the prescribed time. — Art. 203, Reg. 33, Revised. U 718 — Paid-up Capital Stock. Paid-up capital stock, to be entered under item 1 , should represent total par value of paid-up stock issued, both com- mon and preferred, outstanding at the close of the period covered by the return. It is immaterial whether stock is paid for in cash, promissory notes, or other assets. When stock is assessable on account of deferred payments or is 413 CORPORATIONS— Continued RETURNS payable in installments, the amount actually paid on such shares will constitute the actual paid-up capital stock of the corporation, and the amount so actually paid in will be en- tered under this item. U 71 9 — Indebtedness. Indebtedness, to be entered under item 2, should embrace all outstanding interest-bearing indebtedness for which the corporation has acknowledged liabihty, in the form of mort- gage, note, bond, or other paper, said paper bearing interest, not including indebtedness wholly secured by collateral the subject of sale in the ordinary business of the corporation. Such latter indebtedness should be included under item 6c of the supplementary statement, at the lower margin of the return proper, and should be properly explained. Tj 720 — Banks and Other Financial Institutions. Banks and other financial institutions will include as Gross Income the total revenue, gains, or profits from all sources, as shown by the entries on the books of account. ^ 721 — Manufacturing Corporations. Manufacturing corporations will ascertain Gross Income from operations through the inventory computation on the back of the form. In this computation "Sales" should repre- sent the entire sales during the year, whether for cash or otherwise. "Purchases" should include all purchases of raw material, suppHes, etc., during the same period. "Pur- chases" will not, however, include any expenses or other items claimed as deductions shown by the return. (Pur- chases of equipment, office furniture, fixtures, and so forth, are considered to be capital investments and are not subject to deduction as purchases or expenses.) Such items are to be charged to capital account and are susceptible to depre- ciation charge, which may be taken in the return if. such ac- count is set up on the books of the corporation and so en- tered on the books as to constitute a liability against the assets of the company. "Inventories" should be as of the be- 413 CORPORATIONS— Continued RETURNS ginning and close of the period covered by the return and will embrace finished and unfinished products, raw materials, supplies, etc. If 722 — Mercantile Corporations. Mercantile corporations will ascertain "Gross Income from Operations" in the same manner as manufacturing corpora- tions, except that inventories will embrace merchandise or stock in trade, or on hand, at the beginning and close of the period, as well as the amount of the gross sales and pur- chases during the period. tl 723. — Other Corporations. Other corporations will include as gross income the total revenue derived from the operation and management of the business and property of the corporation, together with all amounts of income, gains, or profits arising or accruing from all other sources, as shown by the books of account. Deductions. Tf 724 — Expenses, General. General expenses should be segregated and entered under the proper heading. The schedule should not include any items that have been taken into consideration in the in- ventory computation when ascertaining the "Gross Income from Operations." The schedule should embrace the expenses of non-produc- tive, supervisory, executive and selling labor, commissions; Light, heat, and power expense; Ordinary rentals ; Incidental repairs, whch do not add to the value or ap- preciably prolong the life of the property, or which do not constitute additions and betterments, the latter being prop- erly chargeable to property account ; Total salaries paid to officers ; And such expenses as are not accounted for in any of the above items, and should be classified under three or four general heads. 414 CORPORATIONS— Continued If 725 — Losses. Losses, to be deductible, must be definite, absolute, actu- ally sustained during the period and will not include shrink- age in the value of securities or other assets. Appropriate explanation should be made in the space pro- vided on the back of the form of each loss for which de- duction is claimed. Decrease in value of stock inventory is not a loss contemplated to be treated here, but will be taken into account in the inventory in the computation of the supplementary statement. Bad debts should be Hsted and date of charging off stated as to each. If the space pro- vided is not sufficient to make such list, use additional paper and securely attach same to the return. Bad debts are not deductible as a loss unless at some time, either through in- ventory or otherwise, they shall have been taken up as income. K 728 — Depreciation Deductions. Depreciation deductions should be appropriately explained. If depreciation is claimed on more than one class of property at different rates, the cost of each separate class will be stated, with its corresponding probable life, the amount charged off this and prior years. The amount deducted must appear on the books of the corporation as a liability against the assets, and must be reflected in the annual "Bal- ance Sheet." Depreciation on merchandise or stock in trade must not be deducted here, but should be taken into consid- eration through the inventory at the close of the year. De- duction as depreciation cannot be taken for such wear and tear as has been made good by repairs. The depreciation deduction cannot be cumulative, but will consist of an amount measuring the loss due to use, wear and tear occur- ring during the period for which the return is made. 11 727 — Interest Deductions. Interest deductions should include only that paid or ac- crued within the taxable year on its indebtedness except on indebtedness incurred or continued to purchase or carry obligations or securities (other than obligations of the United States issued after September 24, 1917) the interest 415 CORPORATIONS— Continued upon which is wholly exempt from taxation under this title as income to the taxpayer. ^ 728 — Receivers, Trustees or Assignees of Corporations to Make Return. Section 13, paragraph C, of this title requires receivers, trustees in bankruptcy, or assignees, who are in charge of and are operating the property and business of corporations, to make returns of annual net income and pay any income tax thereby shown to be due, regardless of what disposition, subject to the orders of the court, may be made of such income. Notwithstanding the fact that the powers and functions of the corporation are suspended and that the property and business are for the time in control and custody of the re- ceiver, trustee, or assignee, subject to the orders of the court, such receiver, trustee, or assignee stands in the place of the corporate officers and is required for the purpose of this title to perform all the duties and assume all the liabili- ties which would devolve upon the officers of the corporation were they in control. The income which he receives on ac- count of the business transacted is the income of the cor- poration and, no matter how such income is appHed, it is subject to the tax imposed by this title in so far as it ex- ceeds the deductions or allowances authorized by law. The receiver, trustee, or assignee acting for the corpora- tion, is required to make a true and accurate return of an- nual net income covering each year or part of each year during which he is in custody and control of the business or properties and will be liable to all the penalties imposed by this title for failure to meet any of its requirements. — Art. 209, Reg. 33, Revised. ^729 — Prescribed Forms. Returns made under this Act and pursuant to these in- structions must be made on the forms prescribed by this department for each particular year, and which are avail- able at the offices of collectors. 416 CORPORATIONS— Continued It 730— Tentative Returns. In the absence of a prescribed form a statement made by a corporation disclosing its gross income and deductions there- from may be accepted as a tentative return, and if filed within the prescribed time a return so made will relieve the corporation from liability to the penalties imposed by law, provided that upon request and without delay such tentative return be substituted by a return made on the regular form. — Treasury Decision 2137. ][ 731— Failure to Pay Tax. If any tax remains unpaid after the date when it is due, and for ten days after notice and demand by the collector, then, except in the case of estates of insane, deceased, or in- solvent persons, there shall be added as part of the tax the sum of 5 per cent, on the amount due but unpaid, plus interest at the rate of 1 per cent, per month upon such amount from the time it became due. If 732— Failure to File Return. In case of any failure to make and file a return within the time prescribed by law, or prescribed by the Commissioner of Internal Revenue or the collector in pursuance of the law, the Commissioner of Internal Revenue shall add to the tax 25 per cent, of its amount. If 733— Reasonable Cause and Not Willful Neglect. When a return is filed after the time required by law (March 15th, unless extension is granted) and it is shown that the failure to file was due to a reasonable cause and not willful neglect, no such addition shall be made to the tax. Tf 734 — False or Fraudulent Return. In case a false or fraudulent return is made, the Com- missioner of Internal Revenue shall add to the tax 50 per cent, of its amount. H 735— Specific Penalty. Any individual, corporation, or partnership required under this title to pay or collect any tax, to make a return or to supply information, who fails to pay or collect such tax, 417 CORPORATIONS— Continued to make such return, or to supply such information at the time or times required under this title, shall be liable to a penalty of not more than $1,000. ^ TSe—Willf uUy Refuses to File Return. Any individual, corporation or partnership, or any officer or employe of any corporation or member or employe of a partnership, who willfully refuses to pay or collect such tax, to make such return, or to supply such information at the time or times required under this title, or who willfully refuses to pay or collect such tax, to make such return, or to supply such information at the time or times required imder this title, or who willfully attempts in any manner to defeat or evade the tax imposed by this title, shall be guilty of a misdemeanor and shall be fined not more than $10,000 or imprisoned for not more than one year, or both, together with the cost of prosecution. Tf 737 — Verification of Return. For the purpose of verifying the accuracy of a return, or for making one where none is made, the books of corpora- tions and all other relative data shall be open to the inspec- tion of the Commissioner of Internal Revenue or his duly authorized agents. — Art. 221, Reg. 33, Revised. ^ 738— Tax Not to Be Re-collected When Once Paid. That where any tax heretofore due and payable has been duly paid by the taxpayer, it shall not be re-collected from any withholding agent required to retain it at its source, nor shall any penalty be imposed or collected in such cases from the taxpayer, or such withholding agent whose duty it was to retain it, for failure to return or pay the same, un- less such failure was fraudulent and for the purpose of evad- ing payment. If 739 — Refund of Portions of Amounts Accepted in Compromise Under Law. On March 4, 1915, Congress authorized the Commissioner of Internal Revenue to refund to corporations all amounts paid by them in compromise on account of their failure to 418 CORPORATIONS— Continued make returns in the income tax year of 1913 so paid in ex- cess of $10 ; also to refund, as to said tax year, all amounts paid as penalties by corporations required to make return but which, in their nature, are not subject to the income tax. — Treasury Decision 2175. The Act covers only amounts paid as offers in compromise and accepted by the United States for the year 1913 and has no reference to the 25 per cent, or 5 per cent, penalties col- lected under the law. ^ 740—50 Per Cent. Penalties. If a party Hable to tax for entire year falsely states that he is hable for only a portion of the year, return so made is false and 50 per cent, penalty applies in full. 11741—25 Per Cent. Penalty for Failure to File Return is Mandatory. Government officers have no discretion to remit penalty for failure to file return. T[ 742 — Penalty for Giving Information from Withholding Returns. The law is specific and mandatory with regard to safe- guarding from publicity the information acquired by reason of its requirements relative to annual returns of income. The law imposes the penalty of "fine, imprisonment, dis- missal from office, and forfeiture of right to hold office," for making known in any manner not provided by law the amount or source of income, or any particular thereof, set forth or disclosed in any income return by any person. II 743 — False Returns. There is no necessity to construe the word "false" where it is used with reference to the time in which Commissioner shall act, to mean fraudulently false. ^ 744 — New Corporations — Fiscal Year Returns of — How Made. The Federal income tax law authorizes corporations, joint-stock companies, etc., under certain conditions to make their returns on the basis of an established "fiscal year" or 419 CORPORATIONS— Continued consecutive 12-months period, which may be other than the calendar year. If a taxpayer changes his accounting period from fiscal year to calendar year, from calendar year to fiscal year, or from one fiscal year to another, the net income shall, with the approval of the Commissioner, be computed on the basis of such new accounting period, subject to the following pro- visions : If a taxpayer, with the approval of the Commissioner, changes the basis of computing net income from fiscal year to calendar year a separate return shall be made for the period between the close of the last fiscal year for which return was made and the following December 31. If the change is from calendar year to fiscal year, a separate return shall be made for the period between the close of the last calendar year for which return was made and the date desig- nated as the close of the fiscal year. If the change is from one fiscal year to another fiscal year a separate return shall be made for the period between the close of the former fiscal year and the date designated as the close of the new fiscal year. If a taxpayer making the first return ior income tax keeps his accounts on the basis of a fiscal year he shall make a separate return for the period between the beginning of the calendar year in which such fiscal year ends and the end of such fiscal year. ^ 745 — Computation on Fiscal Year Basis. In all the above cases the net income shall be computed on the basis of such period for which separate return is made, and the tax shall be paid thereon at the rate for the calendar year in which such period is included, and the cred- its allowed shall be reduced respectively to amounts which bear the same ratio to the full credits provided in such sub- divisions as the number of months in such period bears to 12 months. ^ 746 — Amended Instructions for Guidance in Determining Fiscal Year. Pursuant to this provision the following instructions are issued for the guidance of collectors and other interested parties : 420 CORPORATIONS— Continued (As amended by Treasury Decisions 2029 and 2090.) For income-tax purposes, in the absence of designation otherwise, all returns are required to be made on the basis of the calendar year. The statute provides that returns must be made on the basis of a calendar year unless the cor- poration, etc., involved shall designate a fiscal year other than the calendar year in the manner provided by the stat- ute. When the calendar year shall have passed, a return of income for the entire period of such calendar year is then due and must be made out and filed with the proper collector of internal revenue on or before March 15 then next follow- ing. This is true even of corporations and institutions mak- ing return as corporations, except that such corporations, etc., are given the privilege of filing with the collector of internal revenue (with whom their return must be filed) not less than thirty days (more, but not less) prior to March 15 (the date when the return on the basis of a calendar year is to be filed) , a notice, in writing, setting forth that such corporation, etc., has designated the last day of some month in the year (other than the last day of December) as the day of the closing of its fiscal year, and that from the date so desiganted as the close of its fiscal year its books have been or will be kept on the basis of such designated fiscal year. When this said notice is filed with the collector of internal revenue, a return must then be made on or before March 15 for such part of the calendar year elapsed as is not included in the said designated fiscal year, and return for the full designated fiscal year must be made and filed on or before the 15th day of the third month next succeeding the last day of said designated fiscal year. This rule will apply whether the designation affects the future or past, provided always that the return of income cannot cover more than 12 consecutive months. Example : A X B C Y Z Jan. 1 June 30 Dec. 31 Mar. 15 June 30 Aug. 29 AB is calendar year and C is March 15, the time when re- turn on the basis of the calendar year must be filed. At 431 CORPORATIONS—Continued any time not less than 30 days prior to C a corporation may file with the collector with whom its return of income must be filed a notice in writing setting forth that said corpora- tion, etc., has designated the last day of some month in the year (other than December 31) as the day of the close of its fiscal year, as June 30, represented by X ; thereafter, on March 15, a return will be filed for the period AX. XY rep- resents the first designated fiscal year, and for this said fiscal year a return of income must be made (covering the period XY) subsequent to June 30 and on or before Sep- tember 15 ; in other words, the 15th day of the third month next following the close of the fiscal year. Thereafter re- turns of income will be made and filed annually subsequent to June 30, and on or before September 15. — Treasury De- cision 2090. If it shall appear in any case that returns have been made to the collector on the basis of a fiscal year not desig- nated as hereinbefore indicated, the corporation making such returns will be advised that such returns cannot be accepted, but must be made to cover the business of the calendar year. — Art. 215, Reg. 33, Revised. ^ 747 — Collectors Must Make a Record of the Designation of the "Fiscal Year." Collectors of internal revenue receiving notices of the selection and designation of the "fiscal years," as above in- dicated, will make record of the same, recording (a) the name of the corporation or like organization, (b) the date when notice was given, (c) the day designated for the clos- ing of the fiscal year, and (d) the date when the return under such designation must be filed, . . (Remainder superseded by Treasury Decision 2001.) H 74a— Extension Not to Exceed 30 Days. If the failure to file a return or list is due to sickness or absence, the collector may allow such further time, not ex- ceeding thirty days, for making and filing the return or hst. 422 CORPORATIONS— Continued If 749 — Furthen Extension Than 30 Days by Commissioner of Internal Revenue. The Commissioner may grant a reasonable extension of time for fihng returns whenever in his judgment good cause exists and shall keep a record of every such extension and the reason therefor. ^ 750 — Returns Properly Mailed in Time to Reach Collector Not Subject to Penalty Under Certain Conditions. If a return is made and placed in the United States mails in due course, properly addressed, and postage paid, in ample time to reach the office of the collector or deputy collector on or before the last due date, no penalty will be held to at- tach should the return not be actually received by such officer until subsequent to that date. In cases wherein a question may be raised as to whether or not the return was posted in ample time to reach the collector's office on or be- fore the date due, the envelope in which the return was transmitted should be preserved by the collector of internal revenue and forwarded to the Commissioner of Internal Rev- enue with the return. — Art. 220, Reg. 33, Revised. ^751— "Last Due Date" Defined. "Last due date," as used in these regulations, is con- strued to mean the last day upon which a return is required to be filed in accordance with the provisions of the law, or the last day of the period covered by an extension of time granted by the collector or Commissioner of Internal Rev- enue. — Art. 218, Reg. 33, Revised. If 752 — ^When Due Date Falls on Sunday or Legal Holiday. When the last due date as above defined falls on Sunday or a legal holiday the last due date for fihng returns will be held to be the day following such Sunday or legal holiday and the return should be made to the collector not later than such following day, or, if placed in the mails, it should be posted in ample time to reach the collector's office, under ordinary handling of the mails, on or before the date on which the return as here indicated is required to be filed in the office of the collector. — Art. 219, Reg. 33, Revised. 423 CORPORATIONS— Continued T[ 753— -Return of Dividends. Every corporation subject to the tax imposed by this title, and every personal service corporation shall, v^hen required by the Commissioner of Internal Revenue, render a correct return, duly verified under oath, of its payments of divi- dends, stating the name and address of each stockholder, the number of shares owned by him, and the amount of divi- dends paid to him. ^ 754 — Returns by Brokers. Every individual, corporation or partnership doing busi- ness as a broker shall, when required by the Commissioner of Internal Revenue, with the approval of the Secretary, render a correct return duly verified under oath, showing the names of customers for whom such individual, corporation, or partnership has transacted any business, with such de- tails as to the profits, losses or other information which the commisioner may require, as to ecah of such customers, as will enable the Commissioner of Internal Revenue to deter- mine whether all income tax due on profits or gains of such customers has been paid. ^ 755 — Return by Corporations Making Payment of $1,000. All individuals, corporations, and partnerships, in what- ever capacity acting, including lessees or mortgagors of real or personal property, fiduciaries, and employers, making payment to another individual, corporation, or partnership, of interest, rent, salaries, wages, premiums, annuities, com- pensations, remunerations, emoluments or other fixed or de- terminable gains, profits and income (other than payments described in Sections 254 and 255), of $1,000 or more in any taxable year, or in the case of such payments made by the United States, the officers or employes of the United States having information as to such payments and required to make returns in regard thereto by the regulations here- inafter provided for, shall render a true and accurate re- turn to the Commissioner, under such rules and regula- tions and in such form and manner and to such extent as may be prescribed by him, with the approval of the Secretary of the Treasury, setting forth the amount of 424 CORPORATIONS— Continued PAYMENT OF TAX such gains, profits and income, and the name and address of the recipient of such payment. Such returns may be required, regardless of amounts, in the case of payments of interest upon bonds and mortgages or deeds of trust or other similar obligations of corporations, and in the case of col- lections of items (not payable in the United States) of in- terest upon the bonds of foreign countries and interest from the bonds and dividends from the stock of foreign corpora- tions by individuals, corporations, or partnerships undertak- ing as a matter of business or for profit the collection of for- eign payments of such interest or dividends by means of coupons, checks or bills of exchange. When necessary to make effective the provisions of this section, the name and address of the recipient of income shall be furnished upon demand of the individual, corpora- tion or partnership paying the income. The provisions of this section shall apply to the calendar year nineteen hundred and eighteen and each calendar year thereafter, but shall not apply to the payment of interest on obligations of the United States. ^ 756 — Assessment and Payment of Taxes. Unless the tax is withheld at the source it shall be paid in four installments, each consisting of one-fourth of the total amount of the tax. The first installment shall be paid at the time fixed by law for filing the return, namely March 15th, and the second installment shall be paid on the fif- teenth day of the third month, the third installment on the fifteenth day of the sixth month, and the fourth install- ment on the fifteenth day of the ninth month, after the time fixed by law for filing the return. ]f 757 — Payments Where Extension Is Granted. Where an extension of time for fifing a return is granted the time for payment of the first installment shall be post- poned until the date of the expiration of the period of the extension, but the time for payment of the other install- ments shall not be postponed unless the Commissioner so provides in granting the extension. In any case in which the time for the payment of any installment is at the re- 425 CORPORATIONS— Continued PAYMENT OF TAX quest of the taxpayer thus postponed there shall be added as part of such installment interest thereon at the rate of 1/2 of 1 per centum per month from the time it would have been due if no extension had been granted, until paid. If any installment is not paid when due, the whole amount of the tax unpaid shall become due and payable upon notice and demand by the collector. If 758 — Single Payment. The tax may at the option of the taxpayer be paid in a single payment instead of in installments, in which case the total amount shall be paid on or before the time fixed by law for filing the return, or, where an extension of time for fiHng the return has been granted, on or before the expiration of the period of such extension. REFUND OF TAXES FOUND TO HAVE BEEN OVER- PAID UNDER ANY PREVIOUS OR THE PRESENT ACT. If 758(a) - If it is found upon examination of returns made under the provisions of either the present Act or any previous Act, an amount of income, war-profits or excess-profits tax has been paid in excess of the tax properly due, then notwithstanding the provisions of section 3228 of the Revised Statutes, (which provides that claims for taxes wrongfully collected must be presented within two years after the cause of action accrued) the amount of the excess shall be credited against any income, war-profits or excess-profits taxes, or installment thereof, then due from the taxpayer under any other return, and any balance of excess shall be immediately refunded to the taxpayer. Tf 758 (b)— Limitation of Time for Filing Refund Claim. No credit or refund with respect to amounts referred to above shall be allowed or made unless the claim therefor shall have been filed before the expiration of a period of five years from the date the return was due. 426 CORPORATIONS— Continued ^ 759 — Payment of Tax at Source. In all cases where the tax is withheld at the source on income paid to non-resident aliens and on interest on the bonds containing a tax-free clause, the returns shall be filed on or before March 1st of each year and the tax on same shall be paid on or before June 15th. H 760 — False or Fraudulent Return. In the case of a false or fraudulent return filed by a corporation, the Commissioner, upon the discovery thereof shall make a return at any time after the return is filed, upon information obtained, and the tax may be collected at any time after it becomes due. ^ Except in the case of false or fraudulent returns with intent to evade the tax, the amount of tax due under any return shall be determined and assessed by the Commis- sioner within five years after the return was made, and no suit or proceeding for the collection of any tax shall be begun after the expiration of five years after the date when the return was due or was made. Tf 761— Past Due Taxes Voluntarily Paid. If the corporation against which additional tax liability is discovered will formally accept the findings of the exam- ining officer and agree to voluntarily pay the additional tax to the collector of internal revenue and does so pay the additional tax, amended returns or waivers will not be required. — Art. 234, Reg. 33, Revised. If 762— Refunds. That if, upon examination of any return of income made pursuant to this Act, the Act of August 5, 1909, entitled "An Act to provide revenue, equalize duties, and encourage the industries of the United States, and for other purposes," the Act of October 3, 1913, entitled "An Act to reduce tariff duties and to provide revenue for the Government, and for other purposes," the Revenue Act of 1916, as amended, or the Revenue Act of 1917, it appears that an amount of income, war-profits or excess-profits tax has been paid in excess of that properly due, then, notwithstanding the pro- visions of Section 3228 of the Revised Statutes, the amount 427 CORPORATIONS— Continued of the excess shall be credited against any income, war- profits or excess-profits taxes, or installments thereof, then due from the taxpayer under any other return, and any balance of such excess shall be immediately refunded to the taxpayer. That no such credit or refund shall be allowed or made after five years from the date when the return was due, unless before the expiration of such five years a claim therefor is filed by the taxpayer. K 763— Uncertified Checks. Under rules and regulations prescribed by the Secretary of the Treasury, collectors of internal revenue may receive, at par with an adjustment for accrued interest, certificates of indebtedness issued by the United States, and uncer- tified checks in payment of income, war-profits and excess- profits taxes, during such time and under such regulations as the Commissioner of Internal Revenue, with the approval of the Secretary of the Treasury, shall prescribe; but if a check so received is not paid by the bank on which it is drawn, the person by whom such check has been tendered shall remain liable for the payment of the tax and for all legal penalties and additions, the same as if such had not been tendered. 11 764— Failure to Pay Tax When Due. Upon failure to pay the tax when due and for 10 days after notice and demand, a penalty of 5 per cent, of the amount of the tax unpaid and interest at the rate of 1 per cent, per month until paid shall be added to the amount of such tax. ^ 76B— 5 Per Cent. Penalty Waived Upon Filing Claim. To any amount of tax which is subject to a bona fide claim for abatement such sum of 5 per cent, shall not be added and the interest from the time the amount was due until the claim is decided shall be at the rate of one-half of 1 per cent per month. ^ 766 — Returns to Be Public Records. That returns upon which the tax has been determined by the Commissioner shall constitute public records; but 423 CORPORATIONS— Continued they shall be open to inspection only upon order of the President and under rules and regulations prescribed by the Secretary and approved by the President. ^ 767 — Information to States Which Impose Income Taxes. The proper officers of any State imposing an income tax may, upon the request of the Governor thereof, have access to the returns of any corporation, or to an abstract thereof showing the name and income of the corporation, at such times and in such manner as the Secretary may prescribe : Provided further. That all bona fide stockholders of record owning 1 per centum or more of the outstanding stock of any corporation, shall, upon making request of the Commis- sioner, be allowed to examine the annual income returns of such corporation and of its subsidiaries. Any stockholder who pursuant to the provisions of this section is allowed to examine the return of any corporation, and who makes known in any manner whatever not provided by law the amount of source of income, profits, losses, ex- penditures, or any particular thereof, set forth or disclosed in any such return, shall be guilty of a misdemeanor and be punished by a fine not exceeding $1,000, or by imprison- ment not exceeding one year, or both. The Commissioner shall as soon as practicable in each year cause to be prepared and made available to public inspection in such manner as he may determine, lists con- taining the names and the post-office addresses of all in- dividuals making income tax returns. ^ 768 — Regulations Governing the Inspection of Returns by Corporations. See Treasury Decision 2016. ^ 769 — Publicity of Supplementary Statements — The supplementary statement which is made a part of the return form prescribed for the use of corporations in making returns of annual net income is by express terms made a part of the return, and to the same extent that the return constitutes a public record and is open to inspection, to that extent the supplementary statement is also a public 439 CORPORATIONS— Continued record and open to inspection "only upon the order of the President under rules and regulations prescribed by the Secretary of the Treasury and approved by the President." If 770 — Certified Copies of Returns. At the request of the Attorney General or a United States district attorney, certified copies of returns may be made by the Commissioner of Internal Revenue and delivered to the United States district attorneys for their use as evi- dence in the prosecution or defense of suits in which the collection or legality of the income tax assessed on the basis of such returns is involved, or, by special permission of the Secretary of the Treasury, such certified copies of returns may be furnished as evidence in any suit to which the United States Government and the corporation, etc., mak- ing the returns are parties, or as evidence before any United States grand jury, and in which, in the opinion of the At- torney General, such certified copies would constitute material evidence. — Treasury Decision 2016 ; also. Art. 227, Reg. 33, Revised. ]| 771 — Disclosure of Return — Penalty. The disclosure by a collector, deputy collector, agent, clerk, or other officer or employe of the United States, to any person not legally authorized to receive the same, of any information whatever contained in or set forth by any return of annual net income made pursuant to this Act, is, by the Act, made a misdemeanor, and is punishable by a fine not exceeding $1,000, or by imprisonment not exceeding one year, or both, in the discretion of the court, and if the offender is an officer or employe of the United States he shall be dismissed and be incapable thereafter of holding any office under the United States Government. — Art. 229, Reg. 33, Revised. U 772— Publication of Statistics. That the Commissioner, with the approval of the Sec- retary, shall prepare and publish annually statistics reason- ably available with respect to the operation of the income, war-profits and excess-profits tax laws, including classifi- cations of taxpayers and of income, the amounts allowed 430 CORPORATIONS— Continued as deductions, exemptions, and credits, and any other facts deemed pertinent and valuable. ^ 773 — Citizens of United States Possessions. That any individual who is a citizen of any possession of the United States (but not otherwise a citizen of the United States), and who is not a resident of the United States, shall be subject to taxation under this title only as to income derived from sources within the United States, and in such case the tax shall be computed and paid in the same manner and subject to the same conditions as in the case of other persons who are taxable only as to income derived from such sources. ^ 774 — Bookkeeping. No particular system of bookkeeping or accounting will be required by the department. However, the business transacted by corporations must be so recorded that each and every item set forth in the return of annual net income may be readily verified by an examination of the books of account. A corporation keeping accounts upon any basis other than that of actual receipts and disbursements, unless such other basis does not clearly reflect its income, may, subject to regulations made by the Commissioner of Internal Revenue, with the approval of the Secretary of the Treasury, make its return upon the basis upon which its accounts are kept, in which case the tax shall be computed upon its income as so returned. % 775 — Accrued Interest Deductible from Gross Income. The above provision of law authorizes corporations keep- ing books of account on an accrued basis to deduct from gross income in returns of annual net income the accrual of interest for the return year within the limits prescribed by the taxing acts when shown as a charge against accrued income upon the books of account. — Treasury Decision 2625. ^ 776 — Books of Account Best Guide to Income. The books of a corporation are assumed to reflect the facts as to its earnings, income, etc. Hence they will be 431 CORPORATIONS— Continued taken as the best guide in determining the net income upon which the tax imposed by this Act is calculated. Except as the same may be modified by the provisions of the law, wherein certain deductions are limited, the net income dis- closed by the books and verified by the annual balance sheet, or the annual report to stockholders, should be the same as that returned for taxation. Tf 777 — Porto Rico and Philippine Islands. That in Porto Rico and the Philippine Islands the income tax shall be levied, assessed, collected, and paid in accord- ance with the provisions of the Revenue Act of 1916 as amended. Returns shall be made and taxes shall be paid under Title I. of such Act in Porto Rico or the Philippine Islands, as the case may be, by (1) every individual who is a citizen or resident of Porto Rico or the Philippine Islands or de- rives income from sources therein, and (2) every corpora- tion created or organized in Porto Rico or the Philippine Islands or deriving income from sources therein. An indi- vidual who is neither a citizen nor a resident of Porto Rico or the Philippine Islands but derives income from sources therein, shall be taxed in Porto Rico or the Philippine Islands as a non-resident alien individual and a corporation created or oi:ganized outside Porto or the Philippine Islands and deriving income from sources therein shall be taxed in Porto Porto Rico or the Philippine Islands. For the purpose of the deductions and credits provided in Section 234 and paragraph 6 of Section 216, a tax im- posed in Porto Rico or the Philippine Islands upon the net income of a corporation shall not be deemed to be a tax under this title. The Porto Rican or Philippine Legislature shall have power by due enactment to amend, alter, modify, or repeal the income tax laws in force in Porto Rico or the Philippine Islands, respectively. ^ 778 — Examination of Books. For the purpose of verifying any return, made pursuant to this Act, the Commissioner of Internal Revenue may, by 432 CORPORATIONS— Continued any duly authorized revenue agent or deputy collector, cause the books of such corporation to be examined, and if such examination discloses that the corporation is liable to tax in addition to that previously assessed, or assessable, the same shall be assessed and shall be payable immediately upon notice and demand. For the purpose of such exam- ination, the books of corporations shall be open to the ex- amining officer, or shall be produced for this purpose upon summons issued by any properly authorized officer. if 779 — Additional Assessments. In cases wherein additional assessments are made as a reults of any examination or audit of the return, the tax- payer shall immediately following the making the assess- ment, be notified of the amount thereof, and such taxes shall be paid within 10 days from the date of such notice. — Art. 230, Reg. 33, Revised. 433 THE WAR-PROFITS AND EXCESS-PROFITS TAX IMPOSED BY TITLE III. OF THE REVENUE ACT OF 1918. ^ 780— Definitions. When used in these regulations the terms defined in para- graphs 1 to 6, following, shall, unless otherwise indicated by the context, be deemed to be used only with the scope or meaning ascribed to them respectively in such articles. Tf 781 —Taxable Year. 1. The term "taxable year" means the calendar year, or the fiscal year ending during such calendar year, upon the basis of which the net income is computed. The first taxable year, to be called the taxable year 1918, shall be the calendar year 1918 or any fiscal year ending during the calendar year 1918. If 782— Fiscal Year. 2. The term "fiscal year" means an accounting period of twelve months ending on the last day of any month other than December. If 783 — Personal Service Corporation. 3. The term "personal service corporation" means a cor- poration whose income is to be ascribed primarily to the ac- tivities of the principal owners or stockholders who are themselves regularly engaged in the active conduct of the affairs of the corporation and in which capital (whether in- 435 WAR-PROFITS AND EXCESS-PROFITS TAX. vested or borrowed) is not a material income-producing factor, but does not include any foreign corporation, nor any corporation 50 per centum or more of whose gross in- come consists either (1) of gains, profits, or income derived from trading as a principal, or (2) of gains, profits, commis- sions, or other income, derived from a Government contract or contracts made between April 6, 1917, and November 11, 1918, both dates inclusive. If 784 — Paid or Accrued. 4. The term "paid," for the purposes of the deductions and credits under this title, means "paid or accrued" or "paid or incurred," and the terms "paid or incurred" and "paid or accrued" shall be construed according to the method of accounting upon the basis of which the net income is com- puted under Section 212, which defines net income. T[ 785— Dividends. 5. The term "dividend" means any distribution made by a corporation, other than a personal service corporation, to its shareholders or members, whether in cash or in other property, or in stock of the corporation, out of its earnings or profits accumulated since February 28, 1913, or any such distribution made by a personal service corporation out of its earnings or profits accumulated since February 28, 1913, and prior to January 1, 1918. ^ 786 — Prewar Period. 6. The term "prewar period" means the calendar years 1911, 1912 and 1913, or if a corporation was not in existence during the whole of such period, then as many of such years during the whole of which the corporation was in existence. If 787 — Returns and Payments of Excess-Profits Tax. Returns are to be made by corporations which are not specifically exempt in the same manner and at the same 436 WAR-PROFITS AND EXCESS-PROFITS TAX. times as under the income tax provisions ; and payments are to be made likewise in the same manner and at the same times. ^ 788 — Due Date of Return on Calendar Year Basis. Returns for the calendar year 1918 are due on March 15, 1919, unless an extension is secured, and in such case on the date of the expiration of the extension. If 789 — Due Date of Returns on Fiscal Year Basis. If filed on the basis of a fiscal year, the return and first payment must be made on or before the fifteenth day of the third month following the close of the fiscal year. CORPORATIONS SUBJECT TO THE TAX. If 790 — Corporations. Every domestic corporation which has for the taxable war-profits and excess-profits tax but is required to file a year a net income of less than $3,000 is exempt from the return. Corporations organized for religious, charitable, or educational purposes the profits of which do not inure to any stockholder or individual are also exempt. 11791- Every foreign corporation which has for the taxable year a net income from sources within the United States is, un- less exempt under paragraph 790, required to make a return and to pay the tax, if any. It 792 — Exemptions. The f ollovv^ing are exempt from the tax : (a) Corporations exempt under the provisions of Section 231, Title II. of the Revenue Act of 1918, from the tax 437 WAR-PROFITS AND EXCESS-PROFITS TAX. imposed by such title. (The corporation income tax.) Law, page 79, line 20. (b) Any corporation having a net income of less than $3,000. (c) Income derived from the mining of gold (the remain- ing portion of net income shall be subject to the tax) . Law, page 92, line 11. RATES AND COMPUTATION OF TAX. H 793 — Classification of Net Income. For the purposes of the excess-profits tax, net income which is subject to the tax is that which is derived from a trade or business having invested capital. 11 794— Rate of Tax. The tax upon net income shall, except as otherwise pro- vided, be computed at the following rates : 30 per cent, of the amount of the net income in excess of the excess-profits credit (determined under Section 312, If 827) and not in excess of 20 per cent, of the invested capital ; 65 per cent, of the amount of the net income in excess of 20 per cent, of the invested capital. II 795- The sum, if any, by which 80 per cent, of the amount of the net income in excess of the war-profits credit (deter- mined under Section 311, H 828) exceeds the amount of the tax computed under the first and second brackets. 438 WAR-PROFITS AND EXCESS-PROFITS TAX. 11796- METHOD OF CALCULATING THE WAR EXCESS PROFITS TAX ON CORPORATIONS UNDER TITLE IIL OF THE REVENUE BILL OF 1918. EXAMPLE I. 11797 — Corporation Having an Invested Capital of $1,000,000 and a Net Income for the Calendar Year 1918 of $500,000. FIRST BRACKET— Invested capital $1,000,000 Net income $500,000 8% Excess-profits credit 83,000 8% of invested capital__ $80,000 Amount taxable $417,000 Plus specific exemption- 3,000 Excess-profits credit $83,000 Invested capital $1,000,000 20% 20% of invested capital $200,000 Excess-profits credit 83,000 Amount of net income in excess of excess-profits credit and not in excess of 20% of invested capital, taxable at 30% $117,000 30% Amoimt of tax under First Bracket $35,100 11798- SECOND BRACKET— Net income $500,000 20% of invested capital 200,000 Amount of net income in excess of 20% of invested capital, tax- able at 65% $300,000 65% Amount of tax under Second Bracket $195,000 Plus tax under First Bracket 35,100 Total tax under First and Second Brackets $230,100 439 WAR-PROFITS AND EXCESS-PROFITS TAX. II 799— THIRD BRACKET— Assuming the corporation had an average capital oi $500,000 for the years 1011-1912-1913 (the pre-war period) and an average net income during that period of $100,000, the tax under the third bracket would be as follows : War Profits Credit consists of Specific Exemption $3,000 Aver, net income for pre- war period 100,000 Plus 10% of the difference in the capital (Cap. was $500,000) (now is $1,000,- 000) 50,000 Capital at beginning of year $1,000,000 Pre-war capital 500,000 Increase $500,000 Total War Profits Credit $153,000 10% Increase to be ad- ded $50,000 Net income $500,000 War-profits credit 153,000 Net income in excess of war-profits credit. $347,000 80% 80% of net income in excess of war-profits credit $277,600 Total tax under First and Second Brackets 230,100 Amount by which 80% of the net income in excess of the war-profits credit exceeds the tax as computed under the First and Second Brackets. (This amount to be added to the tax.) $47,500 Plus tax under First and Second Brackets 230,100 Total tax under First, Second and Third Brackets $277,600 11800— Section 302 limits the amount of tax which shall be imposed under the first, second and third brackets. The tax must in no case exceed the sum of the following amounts: $20,000 $500,000 $5,100 3,000 20,000 384,000 $17,000 30% $5,100 $480,000 80% $384,000 440 $389,100 WAR-PROFITS AND EXCESS-PROFITS TAX. IT 801- As the total of this limiting amount is greater than the amount of tax already computed under the first, second and third brackets, no advantage is gained in this case by Section 302, the amount of tax remaining at $277,600. In addition to the War Excess Profits Tax the Corporation Income Tax is as follows: As the net income is $500,000 War Excess Profits Tax (Credit) 277,600 Amount subject to Corporation Income Tax $222,400 Less specific exemption 2,000 220,400 Rate of Income Tax 12% Amount of income tax $26,448 Plus War Excess Profits Tax 277,600 Total taxes $304,048 11802— The above tax of $304,048 is 60 per Cent of the net in- come of $500,000. ^803— When Excess-Profits Credit Exceeds 20 Per Cent, of Invested Capital. In any case in which the full amount of the excess-profits credit determined as provided in Sections 311 and 312 is greater than 20 per cent of the invested capital the part not so allowed shall be deducted from the amount in the second bracket. ILLUSTRATION: IT 804— Capital, $20,000. . Net Income $30,000. Excess profits credit 8 per cent, of capital plus $3,000= $4,600 Amount taxable under first bracket. Difference between credit and 20% of capital. 20 per cent, of capital= 4,000 Amount of credit^ 4,600 As the excess profits credit is greater than the amount taxable in the first bracket there is nothing to tax in the first bracket. 441 WAR-PROFITS AND EXCESS-PROFITS TAX. H 805 — The balance of the credit is then deducted from the amount subject to tax under the second bracket. Amount taxable under second bracket. Difference between total net income and 20 per cent, of capital. Net income $30,000 20 per cent, of capital 4,000 Difference $26,000 Subtract balance of excess profits credit not used in first bracket I 600 Amount taxable in second bracket $25,400 ^ 806 — Limitation of Tax. The tax imposed by the first, second and third brackets as set forth in Section 301 shall in no case be more than 30 per cent, of the amount of the net income in excess of $3,000, and not in excess of $20,000, plus 80 per cent, of the amount of the net income in excess of $20,000. EXAMPLE. Limitation of the tax on a net income of $100,000, Net Income. $20,000 $100,000 $5,100 3,000 20,000 64,000 17,000 80,000 $69,100 30% , 80% $5,100 $64,000 ILLUSTRATION: 11807- Corporation with invested capital of $50,000 and a net income of $25,000, started in business in 1910 with an average capital of $25,000 for the pre-war period (1911- 1912-1913) and an average net income for that period of $10,000. 442 WAR-PROFITS AND EXCESS-PROFITS TAX. COMPUTATION OF TAX. FIRST BRACKET. 30 per centum of the amount of the net income in excess of the excess-profits credit (determined under section 312) and not in excess of 20 per centum of the invested capital. (Sec. 312. That the excess-profits credit shall consist of a specific exemption of $3,000, plus an amount equal to 8 per centum of the invested capital for the taxable year. A foreign corporation shall not be entitled to the specific ex- emption of $3,000.) Invested Capital $50,000 Net Income $25,000 8% Excess Profits Credit— 7,000 8% of Invested Capital $4,000 Amount taxable $18,000 Specific exemption 3,000 Excess Profits Credit $7,000 Invested capital $50,000 20% 20% of invested capital $10,000 Excess-profits credit 7,000 Amount of net income in excess of excess-profits credit and not in excess of 20% of the invested capital taxable at 30% $3,000 30% Amount of tax under First Bracket $900 If SOS- SECOND BRACKET. 65 per centum of the amount of the net income in excess of 20 per centum of the invested capital. Net Income $25,000 20% of Invested Capital 10,000 Amount of net income in excess of 20% of invested capital, tax- able at 65% $15,000 65% Tax under Second Bracket $9,750 Plus tax under First Bracket 900 Tax under First and Second Brackets $10,650 ^ 809(a)— THIRD BRACKET. The sum, if any, by which 80 per centum of the amount of the net income in excess of the war-profits credit (deter- 443 WAR-PROFITS AND EXCESS-PROFITS TAX. mined under Section 311) exceeds the amount of the tax computed under the first and second brackets. TI810— (Sec. 311. That the war-profits credit shall consist of the sum of (1) A specific exemption of $3,000, and (2) An amount equal to the average net income of the corporation for the pre-war period, plus or minus, as the case may be, 10 per centum of the difference between the average invested capital for the taxable year. If the tax is computed for a period of less than twelve months such amount shall be reduced to the same proportion thereof as the number of months in the period is of twelve months. 11811- (b) If the corporation had no net income for the pre- war period, or if the amount computed under paragraph (2) of subdivision (a) is less than 10 per centum of its invested capital for the taxable year, then the war-profits credit shall be the sum of (1) A specific exemption of $3,000, and (2) An amount equal to 10 per centum of the invested capital for the taxable year. If 812— (c) If the corporation was not in existence during the whole of at least one calendar year during the pre-war period, then the war-profits credit shall be the sum of (1) A specific exemption of $3,000, and (2) An amount equal to the same percentage of the in- vested capital of the taxpayer for the taxable year as the average percentage of net income to invested capital, for the pre-war period of corporations engaged in a trade or business of the same general class as that conducted by the taxpayer; but such amount shall in no case be less than 10 per centum of the invested capital of the taxpayer for the taxable year. Such average percentage shall be determined by the Commissioner on the basis of data contained in re- turns made under Title II. of the Revenue Act of 1917 and 444 WAR-PROFITS AND EXCESS-PROFITS TAX. the average known as the median shall be used. If such average percentage has not been determined and published at least 30 days prior to the time when the return of the taxpayer is due, then for purposes of such return 10 per centum shall be used in lieu thereof ; but such average per- centage when determined shall be used for the purposes of Section 250 in determining the correct amount of the tax. 11813- (d) The war-profits credit shall be determined in the manner provided in subdivision (b) instead of in the manner provided in subdivision (c) in the case of any corporation which was not in existence during the whole of at least one calendar year during the pre-war period, if (1) a majority of its stock at any time during the taxable year is owned or controlled, directly or indirectly, by a corporation which was in existence during the whole of at least one calendar year during the pre-war period, or if (2) 50 per centum or more of its gross income (as computed under Section 233 for income tax purposes) consists of gains, profits, com- missions, or other income, derived from a Government con- tract or contracts made between April 6, 1917, and Novem- ber 11, 1918, both dates inclusive. tf814- (e) A foreign corporation shall not be entitled to a specific exemption of $3,000. War Profits Credit as determined under section 311 con- sists of: Specific Exemption $3,000 Average net income for pre-war period 10,000 Plus 10% of the difference in capital (was $25,000 pre-war period— taxable year, $50,000) 2,500 $15,500 Net Income $25,000 War Profits Credit 15,500 Net Income in Excess of War Profits Credit $9,500 80% 80% of net income in excess of War Profits Credit $7,600 Total tax under First and Second Brackets 10,650 445 WAR-PROFITS AND EXCESS-PROFITS TAX. As the tax computed under the first and second brackets exceeds the tax computed under the third bracket, there is no addition to the tax to be made under the third bracket. 1181 Bi- section 302 hmits the amount of tax which shall be im- posed under the first, second and third brackets. The tax must in no case exceed the sum of the following amounts: 30 per cent of the amount of the net income in excess of $3,000, and not in excess of $20,000, plus 80 per cent of the net income in excess of $20,000. $20,000 $25,000 $5,100 3,000 20,000 4,000 $17,000 $5,000 $9,100 30% 80% $5,100 $4,000 As the excess-profits tax now stands it is $10,650 as com- puted under the first and second brackets, but as the limiting amount as shown by the computation under Section 302 is $9,100, the actual amount of the excess-profits tax due is the latter amount of $9,100. In addition to the excess-profits tax the corporation is liable for a corporation income tax upon the net income, less the amount of the excess-profits tax and a specific ex- emption of $2,000. The corporation income tax would be as follows : Net income $25,000 Less excess-profits tax 9,100 $15,900 Less specific exemption 2,000 Amount subiect to corporation income tax $13,900 12% Amount of corporation income tax $1,668 Plus amount of excess-profits tax 9,100 Total tax payable $10,768 This total tax of $10,768 upon a net income of $25,000 is 43 per cent. 446 WAR-PROFITS AND EXCESS-PROFITS TAX. If 81 7 — Where Tax Cannot be Satisfactorily Determined. Where the tax is determined under Section 328 the same shall be deemed to be an amount which bears the same ratio to the net income of the taxpayer (in excess of the specific exemption of $3,000) for the taxable year, as the average tax of representative corporations engaged in a like or simi- lar trade or business bears to their average net income in excess of the specific exemption of $3,000) for such year. 11818- In the case of a foreign corporation the tax shall be com- puted without deducting the specific exemption of $3,000, either for the taxpayer or the representative corporation. 1f8ia— In computing this tax the Commissioner shall compare the taxpayer only with representative corporations whose invested capital can be satisfactorily determined under Section 326, and which are, as nearly as may be, similarly circumstanced with respect to gross income, net income, profits per unit of business transacted and capital employed, the amount and rate of war-profits or excess-profits, and ail other relevant facts and circumstances. 11820— (b) For the purposes of subdivision (a) the ratios be- tween the average tax and the average net income of rep- resentative corporations shall be determined by the Com- missioner in accordance with regulations prescribed by him with the approval of the Secretary. 11821- In cases in which the tax is to be computed under this section, if the tax as computed without the benefit of this section is less than 50 per centum of the net income of the taxpayer, the installments shall in the first instance be computed upon the basis of such tax ; but if the tax so com- puted is 50 per centum or more of the net income, the installments shall in the first instance be computed upon the 447 WAR-PROFITS AND EXCESS-PROFITS TAX. basis of a tax equal to 50 per centum of the net income. In any case, the actual ratio when ascertained shall be used in determining the correct amount of the tax. If the correct amount of the tax when determined exceeds 50 per centum of the net income, any excess of the correct installments over the amounts actually paid shall on notice and demand be paid together with interest at the rate of i^ of 1 per centum per month on such excess from the time the install- ment was due. If 822— Computation of Tax for Fiscal Year, Part of Which Falls Within Calendar Year 1917. If a corporation (other than a personal service corpora- tion) makes a return for a fiscal year beginning in 1917 and ending in 1918, the tax for the first taxable year shall be the sum of the same proportion of a tax for the entire period computed under the Revenue Act of 1917 which the portion of such period falling within the calendar year 1917 is of the entire period, and the same proportion of a tax for the entire period computed under the Revenue Act of 1918 which the portion of such period falling within the calendar year 1918 is of the entire period. ^ 823 — Computation of Tax for Period of Less Than 12 Months. If the tax is computed for a period of less than 12 months, the war-profits credit will be reduced to the same proportion thereof as the number of months in such period bears to 12 months. 11 824— Void— [Ed.] 11825- Any amount heretofore or hereafter paid on account of the tax imposed for such fiscal year by Title II. of the Rev- enue Act of 1917 shall be credited toward the payment of the tax imposed for such fiscal year by this title, and if the amount so paid exceeds the amount of the tax imposed by this title, the excess shall be credited or refunded to the corporation in accordance with the provisions of Section 252. 448 WAR-PROFITS AND EXCESS-PROFITS TAX. In other words, the amount paid for the period between January 1, 1918, and the end of the fiscal year ending in 1918, shall be a credit against the amount of the tax due as ascertained under the Revenue Act of 1918. COMPUTATION OF THE DEDUCTION. ^ 826 — Trade or Business Having Invested Capital. The war-profits credit and excess-profits credit used in computing the rates of tax under Section 301 shall, except in cases coming within the conditions specified in If 817 and 818, be as follows: ^ 827— Excess-Profits Credit. The excess-profits credit shall consist of a specific exemp- tion of $3,000 plus an amount equal to 8 per cent, of the in- vested capital for the taxable year. Example : Invested capital $1,000,000 8% $80,000 Exemption 3,000 Excess-profits credit $83,000 TI 828— War-Profits Credit. The war-profits credit shall consist of a specific exemption of $3,000 and an amount equal to the average net income of the corporation for the prewar period, plus or minus, as the case may be, 10% of the difference between the average 449 WAR-PROFITS AND EXCESS-PROFITS TAX. invested capital for the prewar period and the invested capital for the taxable year. ILLUSTRATION: Net income 1911 $25,000 1912 20,000 1913 30,000 3) $75,000 Average prewar net income $25,000 Invested Capital: 1911 $60,000 1912 80.000 1913 100,000 3) $240,000 Average prewar capital $80,000 Invested capital for taxable year $200,000 Average prewar capital 80,000 Difference (increase) $120,000 10% of difference — $12,000 War-profits credit: Specific exemption $3,000 Average prewar net income 25,000 10% of increase in invested capital 12,000 Total war profits credit $40,000 U 830 — No Net Income for Prewar Period. If the corporation had no net income for the prewar period, for if the amount computed under Section 310(c) is less than 10 per centum of its invested capital for the taxable year, then the war-profits credit shall be the sum of : (1) A specific exemption of $3,000 ; and (2) An amount equal to 10 per centum of the invested capital for the taxable year. U 831 — Corporation Not In Existence During Prewar Period. If the corporation was not in existence during the whole of at least one calendar year during the prewar period, then the war-profits credit shall be the sum of: (1) A specific exemption of $3,000 ; and 450 WAR-PROFITS AND EXCESS-PROFITS TAX. (2) An amount equal to the same percentage of the in- vested capital of the taxpayer for the taxable year as the average percentage of net income to invested capital, for the prewar period, of corporations engaged in a trade or busi- ness of the same general class as that conducted by the tax- payer ; but such amount shall in no case be less than 10 per centum of the invested capital of the taxpayer for the tax- able year. Such average percentage shall be determined by the Commissioner on the basis of data contained in returns made under Title II of the Revenue Act of 1917, and the average known as the median shall be used. If such aver- age percentage has not been determined and published at least 30 days prior to the time when the return of the tax- payer is due, then for purposes of such return 10 per centum shall be used in lieu thereof; but such average percentage when determined shall be used for the purposes of Section 250 in determining the correct amount of the tax. The war-profits credit as defined in Tf 828 shall be deter- mined in the manner provided in Section 3 1 (b) instead of in the manner provided in Section 310(c), in the case of any corporation which was not in existence during the whole of at least one calendar year during the prewar period, or if a majority of its stock at any time during the taxable year is owned or controlled, directly or indirectly, by a corporation which was in existence during the whole of at least one calendar year during the prewar period, or if 50 per cent, or more of its gross income (as computed under Section 233 for income tax pur- poses) which defines Gross Income, consists of gains, profits, commissions, or other income, derived from a Gov- ernment contract or contracts made between April 6, 1917, and November 11, 1918, both dates inclusive. ^ 832 — Foreign Corporations. That in the case of a foreign corporation the specific ex- emption of $3,000 shall not be allowed as excess-profits or war-profits credits. 451 WAR-PROFITS AND EXCESS-PROFITS TAX. ^f 833 — Cases in Which the Commissioner Shall Determine the Tax. In the following cases the tax shall be determined as pro- vided in Section 328. See H 854, also Law p. 96, line 50. (b) In the case of a foreign corporation. (c) Where a mixed aggregate of tangible property and intangible property has been paid in for stock and bonds and the Commissioner is unable satisfactorily to determine the respective values of the several classes of property at the time of payment, or to distinguish the classes of property paid in for stock and for bonds, respectively. 11 834— (d) Where upon application by the corporation, the Com- missioner finds and so declares of record that the tax if de- termined without benefit of this Section would, owing to ab- normal conditions affecting the capital or income of the cor- poration, work upon the corporation an exceptional hard- ship evidenced by gross disproportion between the tax com- puted without benefit of this Section and the tax computed by reference to the representative corporations specified in Section 328 shall not apply to any case in which the tax (computed without benefit of this Section) is high merely because the corporation earned within the taxable year a high rate of profits upon a normal invested capital nor in which 50 per centum or more of the gross income of the cor- poration for the taxable year (computed under Section 233 of Title II) which defines Gross Income, consists of gains, profits, commissions, or other income, derived on a cost- plus basis from a Government contract or contracts made between April 6, 1917, and November 11, 1918, both dates inclusive. NET INCOME FOR EXCESS-PROFITS TAX. ^ 835 — Dividends Received From a Foreign Corporation Which is Subject to Federal Income Tax. In the case of income derived by a corporation from divi- dends upon the stock of a foreign corporation, part of whose net income is subject to the income tax, there shall be de- 453 WAR-PROFITS AND EXCESS-PROFITS TAX. ducted only that proportion of the dividends received upon such stock which the net income of such foreign corpora- tion from sources within the United States is of its entire net income. H 836— The net income for the calendar years 1911 and 1912 shall be computed upon the same basis and in the same manner as provided in Section 38 of the Act entitled "An Act to pro- vide revenue, equahze duties, and encourage the industries of the United States, and for other purposes," approved August 5, 1909, except that taxes imposed by such Section and paid by the corporation within the year shall be in- cluded ; 11837- For the calendar year 1913 upon the same basis and in the same manner as provided in Section II of the Act en- titled "An Act to reduce tariff duties and to provide reve- nue for the Government, and for other purposes," approved October 3, 1913, except that taxes imposed by Section 38 of such Act of August 5, 1909, and paid by the corporation within the year shall be included, and except that the amounts received by it as dividends upon the stock or from the net earnings of other corporations subject to the tax imposed by Section II of such Act of October 3, 1913, shall be deducted; and If 838— For the taxable year upon the same basis and in the same manner as provided for income tax purposes in Title II of this Act. II 839— The average net income for the pre-war period shall be determined by dividing the number of years within that period during the whole of which the corporation was in existence into the sum of the net income for such years, even though there may have been no net income for one or more of such years. 453 WAR-PROFITS AND EXCESS-PROFITS TAX. INVESTED CAPITAL. 1[ 840 — Invested Capital Defined. Allowance for depletion, depreciation, and obsolescence in computation of invested capital. — The term "invested capital" as used in the Act means the invested capital of the present owner. The basis, or starting point, in the com- putation of invested capital is found in the amount of cash and other property paid in, the original values of such other property being determined in accordance with the rules and regulations. But the computation does not stop with such original entries or amounts ; it must take properly into ac- count the surplus and undivided profits. In the computa- tion of surplus and undivided profits, however, full recog- nition must first be given to expenses incurred and losses sustained from the original organization of the business concern down to the taxable year, including among such expenses and losses a reasonable allowance for exhaustion, wear and tear, or obsolescence of property originally ac- quired for cash or for stock or shares or in any other man- ner. If value appreciation of a kind not subject to income tax has been taken up in the accounts, a deduction must be made in respect of such appreciation so taken up. In the computation of the invested capital for any year full effect must also be given to any liquidation of the original capital. ^841 — Invested Capital Averaged. How to ascertain average invested capital for the year, averaged monthly. — The invested capital for any pre-war or taxable year (or where the tax is computed upon the basis of a period less than one year) , for such period, is the aver- age invested capital for the year or period averaged monthly, according to the following rules : Add the capital for each of the several months during which no change occurs, and the average capital for each month in which a change occurs and divide the total by the number of months in the year or period. To ascertain the capital for any month in which a change occurs multiply the capital as of the first day of the month by the number of days it remains constant and the capital 454 WAR-PROFITS AND EXCESS-PROFITS TAX. after each change by the number of days (including the day on which the change occurs) during which it remains con- stant, add the products, and divide the sum by the number of days in the month. If 842 — Items Not Allowed to be Included in Invested Capital. The law specifies certain items which may not be included in invested capital, namely : 11843— Stocks, bonds (other than obligations of the United States) , or other assets, the income from which is not sub- ject to the excess-profits tax ; or borrowed capital. Tf 844 — Borrowed Capital. The term "borrowed capital" as used in the Act includes not only cash or other borrowed property which can be identified as such, but current Habilities and temporary in- debtedness of all kinds, and any permanent indebtedness upon which the taxpayer is entitled to an interest deduc- tion in computing net income. A corporation which under the income tax law is allowed to deduct only a part of the entire interest paid upon its indebtedness, may include in its invested capital such a proportion of its permanent in- debtedness as the amount of interest upon such indebtedness which the corporation is not allowed to deduct is of the total amount of interest paid upon such indebtedness during the taxable year. ^ 845 — Interest on Indebtedness of a Corporation That is Not Allowable as a Deduction. As an illustration of the above paragraph, assume a cor- poration borrows $50,000 to purchase municipal bonds, the income from which is not subject to tax; the interest on this indebtedness say at 5% or $2,500 is not allowable as a deduction, therefore the corporation is in effect paying a tax on $2,500 of the interest received from the municipal bonds which would otherwise be exempt. In this case a corresponding part of the capital invested in such assets may be included in invested capital. 455 WAR-PROFITS AND EXCESS-PROFITS TAX. If 846 — When Income from Tax-Free Securities Consists Partly of Trading Profits and Partly of Interest, Dividends, Etc. Whenever income consists partly of gains or profits sub- ject to the excess profits tax arising from trading in stocks, bonds, etc., the dividends or interest on which are not sub- ject to such tax, and partly of such dividends or interest, there shall be included in the invested capital an amount which bears the same ratio to the total amount invested in such stocks or bonds as the amount of such gains or profits bears to the total amount of such income. ^ 847 — Treatment of Stock of Foreign Corporations When Held by Domestic Corporations. In the case of domestic corporations holding stock in a foreign corporation part of whose net income is subject to the income tax, there shall be included in invested capital such proportion of the value of the stock in such foreign corporation as the net income of such foreign corporation from sources outside the United States is of its entire net income. H 848 — Construction of Terms "Tangible Property" and "Intangible Property." The term "intangible property" will be construed to mean property of a character similar to good will, trade-marks, patents, copy-rights, secret processes, formulae, trade brands, franchises, etc. With respect to property not clearly of such a character, rulings will be issued as oc- casion may demand to indicate whether it shall be regarded as tangible or intangible. The following classes of property, when paid in for stock or shares in a corporation or partnership, will be regarded as tangible property so paid in: Stocks. Bonds. Bills and accounts receivable. Notes and other evidences of indebtedness. Leaseholds. 456 WAR-PROFITS AND EXCESS-PROFITS TAX. U 849 — Invested Capital of Foreign Corporations. When used with reference to a foreign corporation the term "invested capital" means that proportion of the entire invested capital v^hich the net income from sources within the United States is of the entire net income. ^ 850 — Corporation Reorganized After January 1, 1911. That in the case of the reorganization, consolidation, or change of ownership after January 1, 1911, of a trade or business now carried on by a corporation, the corporation shall for the purposes of this title be deemed to have been in existence prior to that date, and the net income and in- vested capital of such predecessor trade or business for all or any part of the pre-war period prior to the organization of the corporation now carrying on such trade or business shall be deemed to have been the net income and invested capital of such corporation. If such predecessor trade or business was carried on by a partnership or individual the net income for the pre-war period shall, under regulations prescribed by the Commissioner with the approval of the Secretary, be ascertained and returned as nearly as may be upon the same basis and in the same manner as provided for corporations in Title II, including a reasonable deduction for salary or compensation to each partner or the individual for personal services actually rendered. If 851 —Reorganization After March 3, 1917. In the case of the reorganization, consolidation, or change of ownership of a trade or business, or change of ownership of property, after March 3, 1917, if an interest or control in such trade or business or property of 50 per centum or more remains in the same persons, or any of them, then no asset transferred or received from the previous owner shall, for the purpose of determining invested capital, be allowed a greater value than would have been allowed under this title in computing the invested capital of such previous owner if such asset had not been so transferred or received : Provided, That if such previous owner was not a corpora- tion, then the value of any asset so transferred or received 457 WAR-PEOFITS AND EXCESS-PROFITS TAX. shall be taken at its cost of acquisition (at the date when acquired by such previous owner) , with proper allowance for depreciation, impairment, betterment or development, but no addition to the original cost shall be made for any charge or expenditure deducted as expense or otherwise on or after March 1, 1913, in computing the net income of such previous owner for the purposes of taxation. If 852 — Corporations Organized Prior to July I, 1919. In the case of the organization as a corporation before July 1, 1919, of any trade or business in which capital is a material income-producing factor and which was previously owned by a partnership or individual, the net income of such trade or business from January 1, 1918, to the date of such reorganization may at the option of the individual or partnership be taxed as the net income of a corporation is taxed under Titles II and III ; in which event the net in- come and invested capital of such trade or business shall be computed as if such corporation had been in existence on and after January 1, 1918, and the undistributed profits or earnings of such trade or business shall not be subject to the surtax imposed in Section 211, but amounts dis- tributed on or after January 1, 1918, from the earnings of such trade or business shall be taxed to the recipients as dividends, and all the provisions of Titles II and III relating to corporations shall, so far as practicable, apply to such trade or business: Provided, That this paragraph shall not apply to any trade or business the net income of which for the taxable year 1918 was less than 20 per centum of its invested capital for such year: Provided, further. That any taxpayer who takes advantage of this paragraph shall pay the tax imposed by Section 1000 of this Act and by the first subdivision of Section 407 of the Revenue Act of 1916, as if such taxpayer has been a corporation on and after Jan- uary 1, 1918, with a capital stock having no par value. ^ 853 — Computation of Invested Capital, Pre-War Period. If any asset of the trade or business in existence both during the taxable year and any pre-war year is included in the invested capital for the taxable year but is not in- 458 WAR-PROFITS AND EXCESS-PROFITS TAX. eluded in the invested capital for such pre-war year, or is valued on a different basis in computing the invested capital for the taxable year and such pre-war year, respectively, then under rules and regulations to be prescribed by the Commissioner with the approval of the Secretary such re- adjustments shall be made as are necessary to place the computation of the invested capital for such pre-war year on the basis employed in determining the invested capital for the taxable year. |[ 854 — Exceptional Cases in Which the Invested Capital Cannot be Satisfactorily Determined. In such cases the taxpayer may submit to the Commis- sioner of Internal Revenue evidence in support of a claim, and the tax shall be the amount which bears the same ratio to the net income of the taxpayer (in excess of the specific exemption of $3,000) for the taxable year as the average tax of representative corporations engaged in a like or simi- lar trade or business bears to their average net income (in excess of the specific exemption of $3,000) for such year. In the case of a foreign corporation the tax shall be com- puted without deducting the specific exemption of $3,000 either for the taxpayer or the representative corporations. In computing the tax under this section the Commissioner shall compare the taxpayer only with representative cor- porations whose invested capital can be satisfactorily de- termined under Section 326 and which are, as nearly as may be, similarly circumstanced with respect to gross in- come, net income, profits per unit of business transacted and capital employed, the amount and rate of war-profits or excess-profits, and all other relevant .facts and circum- stances. 11 855— Such exceptional cases may consist, among others, of the following : 11856— Where, through defective accounting or the lack of ade- quate data, it is impossible accurately to compute invested capital. 459 WAR-PROFITS AND EXCESS-PROFITS TAX. 11857- Where upon application by a foreign taxpayer the Com- missioner finds that the expense of securing the data neces- sary for the computation of the invested capital would be unreasonable in view of the amount of tax involved, or that it is impracticable to determine either the "entire invested capital" or the "entire net income." U858— Where a mixed aggregate of tangible property and in- tangible property has been paid in for stock or for stock and bonds and the Commissioner is unable to satisfactorily determine the respective values of the several classes of property at the time of payment, or to distinguish the classes of property paid in for stock and for bonds, respec- tively. If 859— Long-established business concerns which by reason of ultra-conservative accounting or the form and manner of their organization would be placed at a serious disadvantage in competing with representative concerns in a like or simi- lar trade or business. 11 860— Where the invested capital is seriously disproportionate to the taxable income as compared with representative cor- porations engaged in a similar trade or business. Such cases may arise through : 11861- The realization in one year of the earnings of capital un- productively invested through a period of years or of the fruits of activities antedating the taxable year; or, II 862— Inability to recognize or properly allow for amortization, obsolescence, or exceptional depreciation due to the present war, or to the necessity in connection with the present war of providing plant which will not be wanted for the pur- poses of the trade or business after the termination of the war. 460 WAR-PROFITS AND EXCESS-PROFITS TAX. PRINCIPLES OF MODERN ACCOUNTANCY ADAPTED TO THE ADJUSTMENTS OF INVESTED CAPITAL. II 863— The question of "Invested CapitaF* is a complicated one, and in order that the taxpayer may benefit to the full extent of the law it is quite essential that he have more than a passing knowledge of accounting as well as being fully ac- quainted with the law and Treasury regulations relating thereto. If the corporation making the return is not fully acquainted with all phases of the law governing "Invested Capital," and especially sufficiently versed in accounting principles to recognize certain features which may be taken advantage of, a return is either made out in which the com- pany is not deducting all the exemption it is entitled to, thereby paying too high a tax, or the return is made out incorrectly and upon examination by the Treasury Depart- ment an amended return is required to be filed. Many corporations making tax returns are not qualified to take full advantage of "Invested Capital" allowed them from a reading of the law and Regulations of the Treasury Department because of the misinterpretation of their appli- cation by the taxpayer. For the benefit of this great num- ber of taxpayers as well as those who do understand thor- oughly the application of the law, it was thought the clearest and most concise way of presenting this subject would be by way of a practical illustration presenting a series of balance sheets and pointing out the various facts in these balance sheets in their relationship to "Invested Capital." It is not intended to bring out in this illustration every point in corporation accounting, as there are conditions which arise in individual corporations which of necessity cannot be dealt with in a statement, which should present conditions common to all. There are differences of opinion upon this subject and corporations who are in doubt about any feature pertaining to this subject should consult some one who has made a thorough study of the matter. 1(864— The illustration presents four balance sheets as noted below, and will show the various facts relating to "Invested 461 WAR-PROFITS AND EXCESS-PROFITS TAX. Capital," as disclosed in the balance sheets of the A Com- pany as at January 1, 1918, and December 31, 1918. The first two balance sheets show the condition of Company A and Company B prior to the purchase of the B company by the A company. uses- No. 1 — Balance sheet of the A Company, a company en- gaged in the business of mining ore. This statement pre- sents the condition of the A Company as at December 31, 1917. 1[ see- No. 2 — Balance sheet of the B Company, a company en- gaged in the business of reducing iron ore to pig iron. This statement presents the condition of the B Company as at December 31, 1917. 1fse7- No. 3 — Balance sheet of the A Company directly after the purchase by the A Company of the B Company. This statement presents the condition of the A Company as at January 1, 1918, the beginning of the taxable year. Tfses— No. 4 — Balance sheet of the A Company as at December 31, 1918, the end of the taxable year. NOTE. — In arriving at the "Invested Capital" in the follo^ring balance sheets it will be noted that reference is made to various schedules appear- ing on Form 1103 (the form in use for the year 1917), dealing with the adjustment of Invested Capital. The subject matter referred to through- out this article is in accordance with the new Revenue Act of 1918, and upon the issuance of the new forms for war-profits and excess-profits tax for the year 1918 by the Department, these form will be filled out to con- form with the adjustments relating to "Invested Capital" as defined in the following paragraphs. 462 WAR-PROFITS AND EXCESS-PROFITS TAX. Tf 869— (No.l) THE A COMPANY Balance Sheet As At December 31, 1917. ASSETS. Capital Assets — Real Estate, Leases, Claims, Shafts, Build- ings, Sidings, etc $10,000,000.00 Less Reserve for Depreciation & Depletion 1,000,000.00 $9,000,000.00 Furniture and Fixtures 25,000.00 Less Reserve for Depreciation 5,000.00 20,000.00 9,020,000.00 11 870— Current Assets — Cash $1,750,000.00 Accounts Receivable $1,000,000.00 Less Reserve for Bad Debts 100,000.00 900,000.00 Notes Receivable 1,500,000.00 Accrued Int. on Notes Rec'able 40,000.00 U. S. Liberty Bonds SVgS 100,000.00 U. S. Liberty Bonds 4s 100,000.00 200,000.00 Inventories: Iron Ore 2,000,000.00 Materials and Supplies 100,000.00 2,100,000.00 6,490,000.00 11871- Good Will . 2,500,000.00 Deferred Charges — Prepaid Insurance, Taxes, etc 100,000.00 Discount on Bonds 180,000.00 Organization Expense ($20,000.00 charged off 150,000.00 430,000.00 $18,440,000.00 463 WAR-PROFITS AND EXCESS-PROFITS TAX. 11 872- LIABILITIES. Capital Stock — Authorized $50,000,000.00 Issued $10,000,000.00 Add Surplus 1,720,000.00 $11,720,000.00 Funded Debt- First Lien 6% Gold Bonds (dated Jan. 1, 1917) 2,000,000.00 Current Liabilities — Notes Payable 1,600,000.00 Accounts Payable 2,000,000.00 Dividend Payable Jan. 10, 1918 400,000.00 Accrued Interest on Bonds 60,000.00 Accrued Interest on Notes Payable 60,000.00 Reserve for Federal Taxes 300,000.00 4,420,000.00 Deferred Credits (Pending settlement of claims) 300,000.00 $18,440,000.00 11873 - ~~ (No. 2) THE B COMPANY Balance Sheet As At December 31, 1917. ASSETS. Capital Assets — Real Estate, Leases, Claims, Shafts, Build- ings, Sidings, etc $15,000,000.00 Less Reserve for Depreciation & Depletion 1,500,000.00 $13,500,000.00 Furniture and Fixtures 25,000.00 Less Reserve for Depreciation 5,000.00 20,000.00 $13,520,000.00 11874- Current Assets — Cash 2,000,000.00 Accounts Receivable 1,000,000.00 Less Reserve for Bad Debts 100,000.00 900,000.00 Notes Receivable 500,000.00 Accrued Int. on Notes Rec'ble 10,000.00 Inventories: Pig Iron 1,500,000.00 Materials and Supplies 200,000.00 1,700,000.00 6,110,000.00 Deferred Charges- Prepaid Insurance, Taxes, etc 150,000.00 Discount on Bonds 270,000.00 Org'ization Expenses ($30,000.00 charged off) 150,000.00 ~ 670,000.00 $19,200,000.00 464 WAR-PROFITS AND EXCESS-PROFITS TAX. 11875-. LIABILITIES. Capital Stock — Authorized and Issued $10,000,000.00 Add Siirplus 1,000,000.00 $11,000,000.00 Funded Debt- First Lien 6% Gold Bonds (dated Jan. 1, 1917) 3,000,000.00 Current Liabilities — Notes Payable 1,500,000.00 Accounts Payable 3,100,000.00 Accrued Interest on Bonds 90,000.00 Accrued Interest on Notes Payable 10,000.00 Reserve foT Federal Taxes 300,000.00 Total Current Liabilities 5,000,000.00 Reserve for Improvements and Contingencies 200,000.00 $19,200,000.00 11876- (No. 3) THE A COMPANY Balance Sheet As At January 1, 1918. ASSETS. Capital Assets — /f Real Estate, Leases, Claims, Shafts, Build- ings, Sidings, etc $61,500,000.00 Less Reserve for Depreciation & Depletion 2,500,000.00 $59,000,000.00 Furniture and Fixtures 50,000.00 Less Reserve for Depreciation 10,000.00 40,000.00 Total Capital Assets 59,040,000.00 Current Assets — Cash 3,850,000.00 Accounts Receivable 2,000,000.00 Less Reserve for Bad Debts 200,000.00 1,800,000.00 U. S. Liberty B'ds 31/38 (First) 1,000,000.00 U. S. Liberty B'ds 4s (Second) 100,000.00 1,100,000.00 Notes Receivable 1,000,000.00 Accrued Interest Receivable — 50,000.00 Inventories : Iron Ore and Pig Iron 3,500,000.00 Materials and Supplies 300,000.00 3,800,000.00 Total Currents Assets.- 11,600,000.00 Good Will 2,500,000.00 Deferred Charges — Prepaid Insurance, Taxes, etc 250,000.00 Discount on Bonds 4,450,000.00 Organization Expense 300,000.00 5,000,000.00 $78,140,000.00 465 WAR-PROFITS AND EXCESS-PROFITS TAX. 11877- LIABILITIES. Capital Stock — Authorized 500,000 shares $50,000,000.00 Issued 200,000 " $20,000,000.00 Add: Earned Surplus 1,720,000.00 Capital Surplus 1,500,000.00 3,220,000.00 $23,220,000.00 Funded Debt — Ten-Year 6% Convertible Gold Bonds dated Jan. 1, 1918 40,000,000.00 1st Lien 6% Gold Bonds A Company dated Jan. 1, 1918 2,000,000.00 1st Lien 6% Gold Bonds B Company dated Jan. 1, 1918 3,000,000.00 45,000,000.00 Current Liabilities — Accounts Payable 5,100.000.00 Notes Payable 3,100,000.00 Dividend Payable (Payable Jan. 10) 400,000.00 Accrued Interest on Bonds 150,000.00 Accrued Interest on Notes Payable 70,000.00 Reserve for Federal Taxes 600,000.00 9,420,000.00 Deferred Credits — Earnings in Litigation 300,000.00 Reserve for Improvements and Contingencies 200,000.00 500,000.00 $78,140,000.00 TI87S- NOTE: On January 1, 1918, the A Company purchased the assets and assumed the liabilities of the B Company: i. e., it purchased the equity of the B Company by issue of capital stock. From the accounting viewpoint when stock is issued in purchase of another company, the surplus of the vendor is eliminated when such assets and liabilities are entered upon the books of the vendee. If the value of the stock issued represents the sum of the capital stock and surplus as shown by the books of the vendor then the assets and liabilities are entered at the same figures on the books of the vendee; if a lesser amount is issued certain of the assets are reduced; if a greater amount, either "Good Will" or "Capital Assets" is increased. In this instance, in order that the reader may readily follow through the statements from one balance sheet to the other, the stock of the A Company is issued at a premium ($115.00 per share) in order that the surplus of the B Company may be entered on the books of the A Company. This is called "Capital Surplus" or "Paid in Surplus." This is done so as to present to the reader "Earned Surplus" as shown by the A Company as at December 31, 1917, and "Paid in Surplus" as at January 1, 1918. This brings in, under Schedule A on page 2 of form 1103 "Capital Stock" as at the beginning of the year and the earned surplus, and also the capital surplus. If stock is sold for cash at a premium it is very clear tnat such premium is paid in surplus, if, however, property other than cash is received it is encumbent upon the taxpayer to show that it actually represents value. (It will be noted that Capital Assets increased by $36,000,000.00, being purchase of properties by issue of 10-year 6% Conv. Gold Bonds at 90.) 466 WAR-PROFITS AND EXCESS-PROFITS TAX. (No. 4) THE A COMPANY Balance Sheet As At December 31, 1918. ASSETS. Capital Assets — Real Estate, Leases, Claims, Shafts, Build- ings, Sidings, etc $70,500,000.00 _ Less Reserve for Depreciation & Depletion 8,600,000.00 $61,900,000.00 Furniture and Fixtures 50,000.00 Less Reserve for Depreciation 20,000.00 30,000.00 Total Capital Assets 61,930,000.00 Investments — The Smith Jones Corporation Common Stock, 2,000 shares 200,000.00 The Smith Jones Corporat'n Preferred Stock, 8,000 shares 800,000.00 Total Investments 1,000,000.00 Sinking Fund Trustee — Cash and Securities . 4,500,000.00 Current Assets — Cash 4,040,000.00 Accounts Receivable 5,000,000.00 Less Reserve for Bad Debts 400,000.00 4,600,000.00 U. S. Lib. Loan Bonds 31/28 (1st) 1,000,000.00 U. S. Lib. Loan Bonds 4s (2nd) 100,000.00 L. S. Lib. Loan Bonds 414 s (4th) 500,000.00 1,600,000.00 Notes Receivable 3,000,000.00 Accrued Interest Receivable— 160,000.00 Inventories : Iron Ore and Pig Iron 6,000,000.00 Materials and Supplies 400,000.00 6,400,000.00 Total Current Assets— 19,800,000.00 Good Will, Patents, etc 2,500,000.00 Deferred Charges — Prepaid Insurance, Taxes and Sundiy Expenses chargeable to future operations 750,000.00 Discount on Bonds 4,005,000.00 Organization Expenses 250,000.00 Total Deferred Charges 5,005,000.00 $94,735,000.00 467 WAR-PROFITS AND EXCESS-PROFITS TAX. 11880-- LIABILITIES. Capital Stock — Autkorized 500,000 shares $50,000,000.00 Issued 320,000 " $32,000,000.00 Add: Surplus Jan. 1, 1918— 1,720,000.00 Income for year 5,015,000.00 6,735,000.00 Less Dividend 3,200,000.00 3,535,000.00 Add Capital Surplus 1,500,000.00 5,035,000.00 $37,035,000.00 Funded Debt— Ten-Year 6% Conrertible Gold Bonds dated Jan. 1, 1918 40,000,000.00 1st Lien 6% Gold Bonds A Company dated Jan. 1, 1917 2,000,000.00 1st Lien 6% Gold Bonds B Company dated Jan. 1, 1917 3,000,000.00 45,000,000.00 Current Liabilities — Accounts Payable 2,200,000.00 Notes Payable 1,500,000.00 Dividend Payable (Payable Jan. 31, 1919)— 555,000.00 Accrued Interest on Bonds 1,350,000.00 Accrued Interest on Notes Payable 95,000.00 Reserve for Federal Taxes 2,000,000.00 Total Current Liabilities 7,700,000.00 Reserve for Sinking Fund 4,500,000.00 Deferred Credits — Earnings in Litigation 200,000.00 Reserve for Improvements and Contingencies 300,000.00 Total Deferred Credits 500,000.00 $94,735,000.00 11881- The Treasury Department blank (Form 1103) which deals with Corporation War Profits and Excess Profits Tax is used for illustration and in the determination of this tax certain exemptions or deductions are allowed from net in- come in order to arrive at the amount of taxable income and to properly determine these deductions, it becomes neces- sary to know the amount of capital employed in the business during the taxable year. Proceeding now with determining the amount of invested capital during the year 1918 of the A Company : 468 WAR-PROFITS AND EXCESS-PROFITS TAX. SCHEDULE A. ^ 882 — Capital Stock and Surplus. In taking up the various features that enter into the capital employed during the taxable year, naturally, the first consideration is given to the Capital Stock and Surplus as at the beginning of the taxable year (January 1, 1918) . In this instance the Capital Stock amounts to $20,000,000.00, the Earned Surplus $1,720,000.00 and Paid-in Surplus $1,500,000.00, and is entered on page 2 (form 1103). The total of Schedule A is transferred to page 1, schedule 1, line 1. Tf 883 — Adjustments During the Year. There are conditions which arise in practically every cor- poration whereby certain changes are made, which affect invested capital during the year; in fact, the capital as shown by the books of the corporation at the beginning of the year may be subject to adjustment (i. e., the amount not allowed as invested capital in accordance with the regula- tions of the Treasury Department). These adjustments may be either by Way of Additions, schedule B, page 2, form 1103, or by Way of Deductions, schedule C, page 3, form 1103. If changes are made during the year such changes are entered under schedule D, page 3, form 1103. If 884 — Reserves Subject to Careful Scrutiny. In the balance sheets of practically every corporation there will appear a number of items as Reserves. In some instances these Reserves are allowable deductions against income, such as Reserve for Depreciation and Reserve for Depletion; but the amounts set up in these Reserves are subject to very careful scrutiny by the Income Tax Depart- ment. If it is found that during the last few years heavy depreciation rates had been set up, but such rates had not been used several years ago, the present amount charged against income would probably be subject to adjustment when deducting from income. At this time we are con- cerned merely with the relationship of these depreciation charges to invested capital. If it is found that in prior years there had been no charge against income for deprecia- 469 WAR-PROFITS AND EXCESS-PROFITS TAX. tion, or only nominal charges, the Treasury Department would probably determine that the amount of assets repre- senting machinery, plants, etc., were over-stated and would compel an adjustment to capital assets to conform with proper depreciation rates covering the assets in question. Such an adjustment should be entered under Schedule C, line 7, Depreciation and Depletion. In the above balance sheets proper Depreciation and Depletion has been set up but attention is directed to it while under the subject of Reserves. ^ 885 — Reserves for Bad Debts, Contingencies and Taxes. There will also be found several Reserves which are not proper deductions against income ; such as Reserve for Bad Debts, Reserve for Contingencies, Reserve for Federal Taxes. These Reserves represent deductions from surplus, but as they are not allowed as deductions against income in determining taxable income; for the purpose of "Invested Capital," the amount reserved should be considered as part of surplus and ordinarily be added to "Earned Surplus," Schedule A, hne 6. In this illustration, however, in order to show under Schedule A the surplus accounts as appearing in the balance sheet, the Reserve adjustments are shown as additions under Schedule B. SCHEDULE B. |[ 886 — Addition to Invested Capital of Reserve for Taxes, Averaged. Reserve for Federal taxes, January 1, 1918, was $600,- 000.00, and it is assumed that payment was made on June 15, 1918, the latest possible date for payment of those taxes. Federal Income and Excess Profits Taxes are not charges against, income or surplus in the sense of being a cost of doing business; they constitute a sharing of the corpora- tion's income with the government, and while it is the gen- eral practice to provide for such taxes by setting up the obligation against the period in which the income accrues, nevertheless, the sum so provided constitutes a setting aside of surplus which is employed in the business until such 470 WAR-PROFITS AND EXCESS-PROFITS TAX. time as actually disbursed. Therefore the amount should be added to surplus as of January 1, 1918, and when dis- bursed considered as a reduction of capital and the amount averaged for the balance of the year and entered as a deduc- tion in red ink under Schedule D. In this instance, as stated above. Surplus in the amounts shown in balance sheet is entered in Schedule A, and this Reserve is shown in Schedule B as an addition ; the $600,000.00 being employed in the business from January 1, 1918, to the date of pay- ment, June 15, 1918, a period of 51/2 months, which gives an average for the year of $275,000.00. If 887 — Reserve for Improvements and Contingencies. Reserve for Improvements and Contingencies at January 1, 1918, was $200,000.00, and at December 31, 1918, $300,- 000.00. This would indicate that out of earnings of 1918 an additional amount was set up dependent upon the amount charged to this Reserve during the year. Assuming that no charges were made against this Reserve, it would then show an additional amount of $100,000 reserved from the profits of 1918, but as this additional amount was taken from the earnings of the taxable year it cannot be taken into consideration for the taxable year. The amount therefore employed during the year is the amount as shown January 1, 1918, viz., $200,000.00, and should be entered in Schedule B as an addition. T[ 888— Reserve for Bad Debts. On January 1, 1918, the amount in this Reserve was $200,000.00, which amount was charged against income in 1917; the Treasury Department rules with reference to Bad Debts that they constitute a deduction against income when ascertained to be a loss and actually charged off on the books as a loss; therefore when the amount shown in Reserve for Bad Debts was charged against income on the books of the corporation it decreased the surplus by that amount, but as the Treasury Department does not allow the deduction against income until actually written off it rep- resents part of the surplus until the bad debt is charged against the Reser^^^e. Assuming that on October 1, 1918, 471 WAR-PROFITS AND EXCESS-PROFITS TAX. a bad debt was charged against this Reserve of $100,000.00 there would be an employment of capital in the business of $200,000.00 for nine months and $100,000.00 for three months, which averaged over the year would give an addi- tional employment of capital of $175,000.00. If 889 — Organization Expenses. Referring to balance sheets of the A Company and the B Company as at December 31, 1917, it will be observed that notation is made that this account decreased by the sum of $20,000.00 A Company and $30,000.00 B Company, a total sum of $50,000.00. Organization Expense is not an allowable deduction wheii computing taxable income, and while many corporations having in mind conservative business principles charge this against income, the Treasury Department has expressly ruled against it as an allowable charge against income and requires that it be capitalized, therefore as the $50,000.00 was charged against income and reduced the surplus by $50,000.00 it should now be added back as Invested Capital. It should be borne in mind, however, that in this illustration the A Company purchased the B Company, and the Treas- ury Department might not permit going back into the affairs of the B Company to make an adjustment of this nature, claiming because of the purchase by the A Company of the B Company the amount of Capital is measured by the Capital issued and Paid-in Surplus. But considering that the stockholders of the B Company are in part stockholders of the A Company so that in point of fact the same relation- ship is still in being, it is concluded that it would be per- fectly proper to likewise consider the Organization Expenses charged off in the B Company as an addition to Capital. (This should be considered as the converse to Sec. 331.) It is impossible to absolutely interpret the law covering every point; the object is to bring up these points for dis- cussion so that the reader will take up any question of this character which he thinks will affect Invested Capital. 472 WAR-PROFITS AND EXCESS-PROFITS TAX. SCHEDULE C. If 890^Value of Donated Stock. There are some conditions affecting Invested Capital that do not appear in a balance sheet, and it becomes necessary at times to investigate entries on the books of the corpora- tion other than those directly shown on the balance sheet. Such an entry would be donated stock and its subsequent sale. Suppose that in the affairs of the A Company certain stockholders returned to the company shares of stock, the par value of which was $1,000,000.00, and these shares of stock were subsequently sold for $750,000.00. Under this circumstance the Treasury Department takes the attitude that stock returned to the corporation as a gift was not issued originally for real value, but an inflated value was placed upon the assets acquired, and the actual capital re- ceived by the corporation was the amount from the sale of the donated stock, in this instance $750,000.00. It is there- fore necessary to enter as a deduction under Schedule C, line 4, the excess amount of par value over amount received, viz., $250,000.00. H 891— Inflated Value of Good Will or Patents. It will be noted that in the balance sheet of the A Com- pany as at December 31, 1917, "Good Will" is entered at $2,500,000.00. In investigating the make-up of this amount it is found that the Directors on July 1, 1917, determined that a certain patent which they possessed for the purpose of mining ore was extremely valuable and added $500,000.00 to the actual cost, crediting the amount to Surplus. In the first instance the credit to Surplus is mis-stated, the amount should have been credited to Capital Surplus. The Treasury Department will not allow this increased valuation of $500,000.00 as Invested Capital, and it should be entered in Schedule C, line 2. II 892 — Overvaluation of Stock. It will be noted in the foot-note in connection with balance sheet as of January 1, 1918, that stock was issued at $115.00 per share, a total value of $11,500,000.00, however, the 473 WAR-PROFITS AND EXCESS-PROFITS TAX. equity of the B Company as measured by its Capital Stock and Surplus was $11,000,000.00, so that the value of the B Company as taken over on the books of the A Company was $500,000.00 in excess of the book value. It is obvious that if the value of the stock of the A Com- pany was $115.00 per share, and if the directors of the A Company valued the equity of the B Company at $11,500,- 000.00, it was perfectly in order for them to issue 100,000 shares of stock, thereby, in fact, paying $11,500,000.00 for the equity of the B Company, however, the law (Sec. 331) states that in any amalgamation, consolidation or change of ownership, if an interest in such trade or business of 50% or more remains in the same persons then no asset trans- ferred shall be allowed at a greater value than allowed to the previous person, therefore under C-5 it will be neces- sary to write back this over-valuation of $500,000.00. SCHEDULE D. T[ 893— Capital Stock. Under date of January 1, 1918, the Capital Stock issued amounted to $20,000,000.00, and on December 31, 1918, amount issued had increased to $32,000,000.00, an addi- tional issue during the taxable year of $12,000,000.00. As- suming that this additional amount of capital was issued on July 1, 1918, the average of this additional capital em- ployed during the year would be $6,000,000.00, and should be entered as an addition to Invested Capital. ^ 894— Dividends. Dividends paid out of earnings or profits during the first 60 days of the taxable year shall be deemed to have been paid from earnings or profits of the preceding years, not out of current earnings. — Law, page 53, line 54. Dividends paid at any time after the first 60 days shaU be deemed to have been paid out of current earnings from the first of the taxable year up to the date of payment. — Law, Page 53, Line 57. It will be noted on balance sheet as of January 1, 1918, under Current Liabilities there is "Dividend Payable'* of $400,000.00 payable January 31, 1918. This covers dividend 474 WAR-PROFITS AND EXCESS-PROFITS TAX. of the A Company declared in 1917, and was charged against surplus of that company ; however, it is capital employed in the business until such time as actually disbursed, there- fore this $400,000.00 is employed in the business for the month of January or 1-12 of the year, an average during the year of $33,333.33. In some corporations this would be a very large amount. II 895— Void— [Ed.] ^f 896 — Deduction of Dividends From Invested Capital. Let us further assume that on March 10, 1918, there was a declaration of dividends of 21/2% or $500,000.00 and hav- ing in mind the law which states that dividends paid at any time after the first sixty days of the taxable year are con- sidered as made from earnings of the taxable year to the date of distribution, and assuming that net income from January 1, 1918, to March 10, 1918, was $100,000.00 the balance of the dividend must then apply against surplus accumulated prior to this year, thereby reducing the sur- plus as of January 1, 1918. Therefore, surplus account would be reduced by $450,000.00, and it would affect the capital employed during the year for 9 and 21-31 months, or an average amount of $362,916.66. This rep- resents a reduction in capital employed and should be en- tered in red ink. Tf 897 — ^Reserve for Sinking Fund Merely a Segregation of Surplus. It will be observed that in the balance sheet of December 31, 1918, there is a reserve for sinking fund amounting to $4,500,000.00. This is not a deduction from income, but merely a segregation of the surplus account for the purpose of eventually retiring bonds in accordance with the mort- gage agreement. It is a setting aside of surplus into a sepa- rate account so that the directors cannot use such amount for the payment of dividends. It, however, is set up out of income of the year 1918, and does not affect invested capital for the year 1918; it should, however, be taken into con- sideration in the following year, 1919, and subsequent years, so long as the reserve for sinking fund appears on the books of the corporation. The sequence to the reserve for sinking 475 WAR-PROFITS AND EXCESS-PROFITS TAX. fund is the account on the opposite side called "Sinking Fund Cash Account and Securities." In this account there will be set aside cash which will be on deposit drawing in- terest, or this cash is invested in securities which will bring in a return, an income. Should this cash be invested in either stocks or bonds, the income of which is not subject to War Excess Profits Tax, then under those circumstances the amount from the date of investment would be considered as a deduction from invested capital. NOTE. — On pages 2 and 3 of the old Form 1103 the matter of Deprecia- tion and Depletion was taken up and if it was found that sufficient depre- ciation had not been deducted during the life of the different properties there had to be an adjustment made in the amount entered under Schedule C, line 7. In this instance in the year 1917 there was a Reserve for Depre- ciation set up on Furniture and Fixtures at the rate of 20%. Such a rate might be considered too high, in which event there must of course be an ad- justment made in the depreciation charged against income and the excess amount charged off should be added back as additional capital and entered under Schedule B. |[ 898 — Corporations Which Shall Not Have the Benefit of Comparison With Similar Corporations. In the case of corporations where the tax is large merely because the corporation earned a high rate of profits upon a normal invested capital, or where 50 per centum or more of the gross income consists of gains, profits, commissions, or other income, derived on a cost-plus basis from Govern- ment contracts made between the date of declaration of war (April 6, 1917), and the signing of the armistice (Novem- ber 11, 1918), both dates inclusive, shall not be accorded the privilege of comparison with corporations engaged in a similar business even though the tax be disproportionately- high. U 89a— Invested Capital. In computing invested capital, every corporation subject to the excess-profits tax shall add together its paid-in capital and its paid-in or earned surplus and undivided profits (under whatever name the same may be called) as shown by its books at the beginning of the taxable year. The total thus obtained shall be adjusted for any asset or item which it covers that is not carried on the books at the valua- tion prescribed by law. When necessary, adjustment (addi- 476 WAR-PROFITS AND EXCESS-PROFITS TAX. tion or subtraction) shall be made in respect of the fol- lowing: ^900 — Adjustments of Invested Capital. Stock or shares issued in the purchase of intangible prop- erty prior to March 3, 1917, which cannot be included in an amount exceeding (a) 25 per cent of the par value of the total stock or shares outstanding on that date, (b) the actual value of such intangible property at the date ac- quired, or the par value of the stock or shares issued in pay- ment therefor, whichever is the lowest. ^ 901 — Limitation on Value of Intangible Assets. The addition to invested capital due to fixing the value of intangible assets must in no case exceed in the aggregate 25 per cent, of the total stock or shares of the corporation outstanding at the beginning of the taxable year. In cases where the Commissioner of Internal Revenue is unable to determine the invested capital because of stock or shares having been issued for a mixed aggregate of tangible and intangible property the tax shall be the amount which bears the same ratio to the net income of the taxpayer (in excess of the specific exemption of $3,000) for the taxable year, as the average tax of representative corporations en- gaged in a like or similar trade or business, bears to their average net income (in excess of the specific exemption of $3,000) for such year. In the case of a foreign corporation the tax shall be computed without deducting the specific exemption of $3,000 either for the taxpayer or the repre- sentative corporations. In computing the tax under this Section the Commissioner shall compare the taxpayer only with representative cor- porations whose invested capital can be satisfactorily deter- mined and which are, as nearly as may be, similarly circum- stanced with respect to gross income, net income, profits per unit of business transacted and capital employed,the amount and rate of war-profits or excess-profits, and all other rel- evant facts and circumstances. Patents and copyrights paid in for stock or shares prior 477 WAR-PROFITS AND EXCESS-PROFITS TAX, to March 3, 1917, must be valued at the amount which is lowest under the following methods : (1) The actual cash value of the patents or copyrights at the date of acquisition ; (2) The par value of the stock issued therefor; (3) Must not exceed in any case in the aggregate 25 per centum of the par value of the stock of the corporation out- standing at the beginning of the taxable year. Tf 902 — Stock or Shares Issued for Tangible Property Other Than Cash. The cash value of tangible property, other than cash, paid in for stock or shares must not exceed the par value of the stock or shares specifically issued therefor, unless the actual cash value of such tangible property at the time paid in is shown to the satisfaction of the Commissioner to have been clearly and substantially in excess of such par value, in which case such excess shall be treated as paid-in surplus. When any stock is returned to the corporation as a gift or for a consideration substantially less than its par value, the stock so returned shall not be treated as a part of the stock issued or exchanged for such property. The proceeds de- rived in cash or its equivalent from the resale of the stock so returned shall, however, be included in the invested capital if retained and employed in the business. TI 903 — Reconstruction of Surplus and Undivided Profits Accounts. Where through failure to provide for depletion, deprecia- tion, obsolescence, or other expenses or losses, or where for any other cause or reason the books of account of the tax- payer do not show the true paid-in or earned surplus and un- divided profits, in the computation of invested capital such adjustments shall be made as are necessary to arrive at a statement of the correct amount. Where a taxpayer claims additions to the capital account, the books of account will be presumed to show the true facts and the burden of proof will rest upon the taxpayer. Such 478 WAR-PROFITS AND EXCESS-PROFITS TAX. additions will be accepted only to the extent and under the conditions stated below: 11904— Amounts which have been expended in the past for the acquisition of plant, equipment, tools, patterns, furniture, fixtures, or Hke tangible property, having a useful Hfe ex- tending substantially beyond the year in which the expendi- ture was made, and which have been charged as current ex- pense, may (less proper reduction for depreciation or obsol- escence) be added to the surplus account in computing in- vested capital when such assets are still owned and in active use by the taxpayer during the taxable year. Special tools, patterns, and similar assets shall not be assigned any value if their cost has been recovered through having been in- cluded in the price of goods. If their cost has not been so recovered and they are held for only occasional use, they shall not be assigned a value in excess of the fair value based upon the earnings actually arising from their current use. Assets of this kind not in current use shall not be valued at more than their nominal or scrap value. U 905 — Valuation of Intangible Property. If good will, trade-marks, trade brands, franchises of a corporation or other intangible property has been purchased with stock or shares issued prior to March 3, 1917, the amount that may be included in invested capital must not exceed (a) 25 per cent, of the par value of the total stock or shares outstanding on that date, nor (b) the actual value of the assets at the date acquired, nor (c) the par value of the stock issued in payment for the assets, whichever is lowest. If 906 — Application of 25 Per Cent Limitation Upon Intangible Property. The 25 per cent, limitation upon intangible property pur- chased prior to March 3, 1917, for or with stock or shares of the corporation, applies not to each item or class of in- tangible property separately, but to the aggregate amount of all such property so purchased. Such intangible prop- erty may be included in the invested capital only up to an 479 WAR-PROFITS AND EXCESS-PROFITS TAX. amount not exceeding 25 per cent of the total stock or shares of the corporation on March 3, 1917, even though the aggregate amount of such intangible property be greater in value than such 25 per cent, of the par value of the total stock or shares. ^807- Intangible property bona fide purchased prior to March 3, 1917, with stock having no par value may be included in invested capital at a value not exceeding the actual cash value of such intangible property at the time of the pur- chase and in an amount not exceeding 25 per cent of the total shares of stock outstanding on March 3, 1917, meas- ured by their value as at the date or dates of issue. 1 908— In the case of any intangible assets acquired prior or sub- sequent to March 3, 1917, the aggregate amount which may be included in invested capital shall not exceed 25 per centum of the par value of the stock or shares outstanding at the beginning of the taxable year. ^ 909 — Surplus or Undivided Profits Earned During Any Year Excluded in Computing Invested Capital for Such Year. Profits earned during any taxable year or pre-war year shall not be included in the computation of the invested capital for such year, even though set up as "surplus" upon the books or distributed in the form of stock dividends. ^ 91 — Scope of Phrase "Surplus and Undivided Profits." Section 326, Article (3) authorizes the inclusion in in- vested capital of earned surplus and undivided profits used or employed in the business. Inasmuch as all the income of a corporation shall be deemed to be received from its trade or business, all the surplus and undivided profits of a corporation (exclusive of undivided profits earned during the year), from whatever source derived, will, unless in- vested in stocks, bonds (other than obligations of the United States) , or other assets, the income from which is not sub- iSC, WAR-PROFITS AND EXCESS-PROFITS TAX. ject to the excess-profits tax, be deemed to be used or em- ployed in the business and may be included in the invested capital. ^911— When Excess Value of Tangible Property May Be Included in Surplus. Where it can be shown by evidence satisfactory to the Commissioner of Internal Revenue that tangible property has been conveyed to a corporation by gift or at a value, ac- curately ascertainable or definitely known as at the date of conveyance, clearly and substantially in excess of the cash or the par value of the stock or shares paid therefor, then the amount of the excess shall be deemed to be paid in surplus. The adopted value shall not cover mineral deposits or other properties discovered or developed after the date of conveyance, but shall be confined to the value accurately ascertainable or definitely known at that time. Evidence tending to support a claim for a paid-in surplus under these circumstances must be as of the date of convey- ance, and may consist, among other things, of (1) an ap- praisal of the property by disinterested authorities, (2) the assessed value in the case of real estate, and (3) the market price in excess of the par value of the stock or shares. If 912— Balance Sheet Must Conform to Reflect Capital Adjustments. Whenever any corrections are made in respect of the capital stock and surplus, corresponding corrections must be made in the respective asset items in the balance sheet of the taxpayer. After making any adjustments required the adjusted to- tal of the capital and surplus account will represent the in- vested capital at the beginning of the taxable year, except that in any case where the admissible assets (and these include all assets except stocks, bonds — other than obli- gations of the United States — ^the income of which is not subject to excess-profits tax) are less than the amount of such adjusted total, then the invested capital must be fur- ther reduced to an amount equal to the sum. of the admis- sible assets. 481 WAR-PROFITS AND EXCESS-PROFITS TAX. If 91 3 — Average Adjustments. If there has been any change made during the taxable year in the amount of the invested capital, the monthly av- erage shall be taken, but in no case may the invested capi- tal include any surplus or undivided profits earned during the taxable year. ILLUSTRATION OF AVERAGE ADJUSTMENTS. 11914— Thus, if the invested capital was $60,000 on January 1, 1918, and was increased on July 15, 1918, by the addition of admissable assets to $100,000, the average capital would be computed as follows : Six months, at $60,000 $360,000.00 July— 14 days, at $60,000 $840,000 17 days, at $100,000 1,700,000 Total $2,540,000 Average for month of July — total divided by 31 81,935.48 Five months, at $100,000 500,000.00 Total for year $941,935.48 Average for year — total divided by 12 $78,494.62 MISCELLANEOUS PROVISIONS. TI 91 S^Fiscal Year Computations. If a corporation (other than a personal service corpora- tion) makes return for a fiscal year beginning in 1917 and ending in 1918, the tax for the first taxable year under this title shall be the sum of: (1) The same proportion of a tax for the entire period computed under Title II of the Revenue Act of 1917 which the portion of such period falHng within the calendar year 1917 is of the entire period, and (2) the same proportion of a tax for the entire period computed under this title at the rates specified in subdivision (a) of Section 301 which the portion of such period falling within the calendar year 1 9 1 8 is of the entire period. 482 WAR-PROFITS AND EXCESS-PROFITS TAX. H 91 e— Amount Paid Under 1917 Act a Credit. Any amount heretofore or hereafter paid on account of the tax imposed for such fiscal year by Title II of the Rev- enue Act of 1917 shall be credited toward the payment of the tax imposed for such fiscal year by this title, and if the amount so paid exceeds the amount of the tax imposed by this title, the excess shall be credited or refunded to the corporation in accordance with the provisions of Section 252. If 91 7 — Proportionate Amount of Tax Payable. (b) If a corporation makes return for a fiscal year be- ginning in 1918 and ending in 1919, the tax for such fiscal year under this title shall be the sum of: (1) the same pro- portion of a tax for the entire period computed under sub- division (a) of Section 301 which the portion of such period falling within the calendar year 1918 is of the entire period, and (2) the same proportion of a tax for the entire period computed under subdivision (b) or (c) of Section 301 which the portion of such period falling within the calendar year 1919 is of the entire period. (c) If a partnership or a personal service corporation makes return for a fiscal year beginning in 1917 and ending in 1918, it shall pay the same proportion of a tax for the entire period computed under Title II of the Revenue Act of 1917 which the portion of such period falHng within the calendar year 1917 is of the entire period. Tf 91 9 — Partnership and Personal Service Refunds. Any tax paid by a partnership or personal service cor- poration for any period beginning on or after January 1, 1918, shall be immediately refunded to the partnership or corporation as a tax erroneously or illegally collected. 11 920— Every corporation, not exempt under Section 304, shall make a return for the purposes of this title. Such returns shall be made, and the taxes imposed by this title shall be paid, at the same times and places, in the same manner, and 483 WAR-PROFITS AND EXCESS-PROFITS TAX. subject to the same conditions, as is provided in the case of returns and payment of income tax by corporations for the purposes of Title II, and all the provisions of that title not inapplicable, including penalties, are hereby made applicable to the taxes imposed by this title. If 921 — Limit of Tax on Profits from Sale of Mines. In the case of a bona fide sale of mines, oil or gas wells, or any interest therein, where the principal value of the property has been demonstrated by prospecting or explora- tion and discovery work done by the taxpayer, the portion of the tax imposed by this title attributable to such sale shall not exceed 20 per centum of the selling price of such prop- erty or interest. If 922— Rates of Tax for the Year 1919. For the year 1919 and subsequent years the excess-profits tax rates are as follows : First bracket — 20 per cent of the net income in excess of the excess profits credit and not in excess of 20 per cent of the invested capital. Second bracket — 40 per cent of the net income in excess of 20 per cent of the invested capital. The total tax shall not exceed the sum of the following : 20 per cent of the net income in excess of $3,000 ; and 40 per cent of the net income in excess of $20,000. Tf 923 — Limitation on Value of Tangible Property Paid in for Stock or Shares. In the case of tangible property paid in for stock or shares the amount to be included in invested capital for the purpose of the tax is the actual cash value of the tangible property at the time of payment; but in no case can this value exceed the par value of the stock or shares specifically issued there- for. 484 WAR-PROFITS AND EXCESS-PROFITS TAX. Treasury Decision 2791. For the Purpose of Determining Invested Capital Under the Act of October 3, 1917, Income and Excess Profits Taxes Deemed to Have Been Paid Out of Earnings of the Year For Which Levied. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned : For the purpose of determining invested capital under Title II of the Act of October 3, 1917, income and excess profits taxes shall be deemed to have been paid out of the net income for the taxable year for which such taxes are levied. Amounts payable on account of income and excess profits taxes for any year may be included in computing surplus and undivided profits for the succeeding years only for the pro- portionate part of the year represented by the period of time between the close of the taxable year and the date or dates upon which such taxes become due and payable. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: February 17, 1919. CARTER GLASS, Secretary of the Treasury. 485 Pages 486 to 1000 In order to hasten delivery of the Manual, this book was printed in two sections, the second section, containing data that was then complete and avail- able, being printed in advance. As it was impossible to calculate at that time how many pages the War Revenue Bill and Digest would occupy, the page numbers of the section containing the Security Prices were started at 1001. Thus folios 486 to 1000 are void. Section IL CONTENTS. High and Low Prices of Stocks and Bonds as of March 1, 1913. Treasury Decisions, Court Decisions, etc. Complete List of Collection Districts. Stock Dividends Paid in 1918. 1001 High and Low Prices of Stocks and Bonds as of March 1, 1913 The Revenue Act of 1918 provides, in part, as fol- lows: "That for the purpose of ascertaining the gain derived or loss sustained from the sale or other disposition of property, real, personal or mixed, the basis shall be : "In the case of property acquired before March 1st, 1913, the fair market price or value of such property as of that date." Although the regulations provide that the depart- ment cannot formulate a method that will determine this value in all cases, and that the value is a ques- tion of fact to be established by any evidence which will reasonably and adequately make it appear, the fair market price or value of securities as of March 1, 1913, is held, in the case of variation between "opening and closing price" for the day, to mean the average price for the day. 1003 Quoted Values of Securities as of March I, 1913 STOCKS High Abbeville Cotton Mills (South Carolina) Acacia (Colorado Springs) Acme Consolidated Acme Steamship *70 Acme White Lead & Color Works, pfd common Acushnet Mill (New Brunswick) Adams Express Adams Gold Fid. Mining (Nev.) Adams Mining Adiron. Electric Power, com preferred Adrian Fence Co Adventure Consolidated Mining Aeolian -Weber, com. preferred Aetna Accident Insurance (Hartford) Aetna Casualty & Surety Aetna Fire Insurance (Hartford) Aetna Life Insurance (Hartford) Aetna National Aetna National Bank (Hartford) Aetna National Bank (New York) Ahmeek Mining Aiken Manufacturing (South Carolina) Alabama Great Southern, com. preferred Ala. N. 0. Tex. & Pac. Jc, pfd. A (par £10) B (par £10) Alabama Traction, Light & Power, com Alamo (Colorado Springs) Alamo National Bank (San Antonio) Alaska Copper 5% Alaska Gold Mines 13% Alaska Packers' Association Alaska Steamship Albany Insurance Albany S. D. & Stor. Albany Southern R. R., com preferred Albany & Susquehana, gtd. Albany Trust (Boston) Albany (New York) Trust Co. Albaugh-Dover Co. Alberta Pacific Grain, pfd. *Quotatlon nearest March 1, 1913. No quotation on that date. 1005 jOW Bid Asked __ __ 75 __ 3c 3%e — Ic 2c II •24% II *27i/4 _^ __ 145 _„ __ 135 145 __ Ic __ 30c __ __ 30c „„ __ 57% 60 *19 31/, 4 25 35 85 95 $275 $285 275 285 349 353 605 515 __ $27 $29 320 195 200 290 300 __ 38 42 $441/2 $461/, $56% $581/, $8 $81/, $% $% $40 $45 .005c __ 190 5% __ 13% __ 90 __ __ *58 $100 $101 125 7 10 23 28 *275 285 $90 $96 190 195 *7i/. __ *100 High Low Bid Asked Alden Mills, com. __ __ 26 ^preferred „ 93 Aldine Fruit Co __ __ __ *110 Aldine Trust (Philadelphia) *125 *125 Algomah Mining ll^ V/^ Alice Gold & Silver Mining *$3.10 *$3.10 Allegheny & Western, gtd. __ __ *130 •138 Allegheny Traction __ __ __ $50 Allegheny (Pa.) Trust *$140 *$140 Allemannia Insurance (Pittsburgh) $110 Allentown National Bank (Allentown) __ __ 158 1591/2 Allentown Portland Cement, com. *3V^ Allentown (Pa.) Trust Co. __ __ $53 $55 Alliance Bank (Rochester) __ 245 255 Alliance Insurance (Philadelphia) __ __ $15% $16 Alliance Realty __ __ $115 $117 AUis-Clialmers, com 14 Cent. Tr. Ctfa., Com., of dep. 3rd Paid— „ __ 3 4l^ Pfd. Cent. Tr. Ctfs. of dep. 3rd Paid __ __ __ 9 All Night & Day Bank (L. A.) __ __ 245 260 Allouez Mining __ __ 36 38 Alpha Mining (Nevada) le Alta Silver Mining (Nevada) 3c Altoona (Pa.) Trust Co. __ __ 200 210 Amalgamated Copper 69% 68l^ Amalgamated Nevada Mines Ic 2c Amalgamated Oil __ __ 86% 86% America, Bank of (New York) __ __ *605 615 American Academy of Music *210y2 *210y2 American Agricultural Chemical, com. 51^/2 SlVg preferred __ 90 99 American Arch Co. . *95 American Assurance, com. __ *13 American Axe & Tool __ __ *24 *30 American Bakery, pfd. __ __ 971/2 common 52 American Bank (Philadelphia) *$60 *$60 American Bank Note, com. __ __ $50 $51 preferred __ __ $53 $54 American Bank & Trust (San Antonio) 110 American Beet Sugar Co., com. 34% 35% preferred __ __ 84 86 American Book _.. __ 170 175 American Brake Shoe & Foundry, com. 90% 95 preferred __ __ 131% 1361/3 American Brass 138 142 American Can, pfd. 124% I241/2 common 35% 35% American Car & Foundry, pfd. 116 116 common 49% 49% American Caramel, com. __ __ 4 10 preferred __ 30 50 American Cement $2 $2% American Central Insurance (St. Louis) — __ __ 148 American Chain, pfd __ — *100 American Chicle, com. 205 210 preferred »_ __ 100 103 American Cigar, com. — 140 147 preferred 85 95 ^Quotation nearest March 1, 1913. No quotation on that date. 1006 High Low American Cities, com. preferred American Coal Co. of Allegheny Co. American Coal Products, com. preferred 1 American Color, pfd. American Colortype, 1st pfd. ■ second preferred common American Cotton Oil, com preferred American Credit Indem American Crude Oil American District Telegraph (New Jersey) American District Telegraph (New York)_> American Dredging Co. American Druggists Syndicate American Exchange National Bank (Dallas) American Exchange National Bank (Duluth) American Exchange National Bank (N. Y.) American Express American Felt Co., pfd. '101 'lOl American Fire Insurance (Philadelphia) $60 American Five & Ten-Cent Store, pfd. __ __ *85 American Fork & Hoe, com. 111 preferred American Fruit Prod., com. preferred American Gas Co. of New Jersey *103 American Gas & Electric, com. preferred I - American Glue, com. preferred American Gold Mining American Graphophone, com ■ preferred American Hardware American Hide & Leather, com. : 414 414 preferred American Hominy, pfd. common American Hosiery American Ice Securities 241/4 2414 American Insurance (Newark) American-La France Fire Eng., com. preferred American Laundry Machine, com American Light & Traction, com preferred American Linen Mills (Fall River) American Linseed, com. preferred American Lithographic, pfd common American Locomotive, com 35% 35% preferred American Lumber American Machine & Foundry *Quotation nearest March 1, 1913. No quotatioD on that date. 1007 Bid Asked 471/2 753/4 $171/2 87 49 77 $25 92 100 1091/2 *90 ~ $1021/2 *90 *31 47 49 96 100 120 30c *50 *53 16 18 350 *1953/4 *13% 325 234 260 1571/2 162 ♦128 4 ~ 25 $84 $86 $44 $451/2 102 IO6I/2 139 144 8c 15c 53 80 136 138 251/2 27 84 85 55 56 $195 ; $215 $26 :: 4 7 40 45 ♦31 400 410 108 110 80 9% 11 27 30 *95 __ *58 ♦64 1041/2 1051/2 ♦621/2 ♦451/4 ♦471/4 High Low American Mail Steamship American Malt Corporation, com. ^preferred American Manufacturing American Marconi (new). American Meter American Multigraph, com. preferred 101 American National Bank (Atlanta) American National Bank (Beaumont) American National Bank (Forth Worth) American National Bank (Louisville) American National Bank (Macon) American National Bank (McAllister) American National Bank (Nashville) American National Bank (Newark) American National Bank (Oklahoma City) — American National Bank (Richmond) American National Bank (St. Paul) American National Bank (San Francisco) American National Bank (Shreveport) American National Bank (Washington) American National Bank (Wilmington, N. C.) American News Co. American Oil Fields American Oriental Co., pfd. common American Petroleum, com. preferred American Piano, pfd. American Pipe & Construction 90 American Pneumatic Service, com. -1st preferred 2nd preferred American Power & Light, com. preferred American Press Association American Public Utilities, pfd. common American Radiator, com. preferred American Railways, com. American Rolling Mill, com. preferre^d American Savings Bank (Los Angeles) American Screw __ ■ __ American Seating Co., pfd. American Security & Trust ( Washington )__ American Seeding Machine, com. preferred American Sewer Pipe *10% American Shipbuilding, com. preferred American Smelting & Refining, com 69% 69 preferred 103% 103% American Smelters Securities, pfd., Ser. B American Snuff, com. preferred American Speaking Telephone Co. 'Quotation nearest March 1, 1913. No quotation on tliat date. 1008 Bid Asked *10 11 12 531/3 56 *130 *132 51/2 5% *110 17 191/2 215 222 300 225 1281/2 198 200 150 183 187 130 130 220 125 133 200 210 170 175 122 123 *29 __ *16 *60 *5 51 65 71 76 *70 *75 Svh $41/4 $493/4 $51 $21 $22 731/2 75 83 86 48 52 751/2 621/2 641/2 500 133 136 $40 $401/2 173 200 1151/2 125 175 154 *20 *30 310 __ 84 97 100 52 54 100 101 85 86 175 190 103 105 -_ *250 High Low Bid Asked American Spinning Co. — 155 American State Bank (Chicago) — __ 210 215 American Steam Gauge & Valve Mfg., pfd. — — — — *105 American Steel Foundries, new stock __ __ 331/3 35 American Sugar Refining, com , — 113 115 preferred __ __ 113 116 American Sumatra Tobacco, pfd. — *73 common' *16% American Surety __ — $100 $102l^ American Telegraph & Cable Co — — *58% *66 American Telegraph Typewriter *40 *47 American Telephone & Telegraph 132% 132% American Textile (Pawtucket) 125 American Thread __ $3y2 $5 American Tobacco, common 240 260 preferred — _- 103^2 104 American Trust Co. (Boston) 350 American Trust (Charlotte) __ 170 American Trust (Morristown) 120 American Trust & Sav. Bank (Birmingham) __ __ 195 200 American Type Founders, com. 46 49 preferred __ 100 103 American Utilities — 10 shares preferred and 5 shares common sold for $1,000, March 1, 1913. American Vanadium Co. *500 American Water Works & Electric, com *55 *60 preferred 97 97^2 American W. Wks. & Guar. (Pittsburgh), pfd. __ __ __ *97y3 common *57V^ *60 American Window Glass, pfd. 42 American Wire Fabrics, pfd. *90 American Woolen, pfd. 77% 771/2 common 17 17i/a American Wririger, com. 106 preferred 116 American Writing Paper, pfd. 28*4 28 common 2 2^4 American Zinc, Lead & Smelting __ 29% 29% Ames-Holden-McCready, pfd. __ __ 781/2 *79 Amherst Gas 145 145 Amoskeag Manufacturing, com. __ __ __ 71 preferred __ __ 9814 99 Anaconda Copper $361/4 $35% Anacostia & Potomac River 5s, 1948 *98i/3 __ guarantee 5s, 1948 *101 Anderson Cotton Mills (South Carolina) 35 45 Andes Silver Mining (Nevada) 4c Andreae Silk (Virginia) __ __ *100 Andrew Jergens, pfd. 105 Androscoggin Mills (Maine) *160 Anglo-American Oil $18 $18l^ Anglo & L. P. National Bank (San Francisco) __ __ 152 I531/2 Anglo California Trust Co. (San Francisco) __ __ __ 125i^ 126l^ Ann Arbor, com. 15 30 preferred 50 80 Annapolis (Maryland) Gas & Elec. Lt., com. __ __ *50 Anthracite Trust (Scranton) *73 *76 Appalachian Power, com. __ 22 23 preferred __ 71% 73 *Quotation nearest March 1, 1913. No quotation on that date. 1009 High Low Bid Asked Appleton Co. (Massachusetts) 'ITS Apsley Rubber, pfd. __ __ __ *iii Ardmore National Bank __ *120 Aristos Co., pfd. __ •12 Arizona Commercial Mining __ 3% 3% Arizona Power, com. __ II1/2 13 preferred j. __ 45 50 Arkansas, Oklahoma & Western Ry., com $8 Arkansas Vy. Ry. Light & Power, pfd _. __ __ 971/3 Arkwright Mills (Fall River) __ __ __ 70 Arkwright Mills (South Carolina) __ __ 95 100 Arlington Fire Insurance __ __ 16 21 Arlington Insurance (Washington) __ $16 $21 Arlington Mills (Massachusetts) 108 112 Arlington Trust (Lawrence) __ __ 125 Armet Moving Pictures *20 Arms Palace Horse Car Co. __ __ *5 Armsby Co. of New York, pfd. __ __ __ 100 Arnold Mining __ i Arsenal Bank (Pittsburgh) 138 Art Metal Cons., com. __ __ __ *170 Arundel Sand & Gravel, pfd __ __ __ *85 Aseptic Products, pfd. __ __ __ *lll^ common __ *15 Assets Realization Co _^ 105 115 Associated Gas & Electric, pfd __ *100 Associated Merchants, 1st pfd. *100 *101 preferred __ ,_ *100 •lOQi/g Associated Oil __ 41 441/2 Astor Trust (New York) __ __ 350 375 Atchison, Topeka & Santa Fe, com. 102 101% preferred 100% 100% Athenaeum of Philadelphia __ *13 Atlanta & Charlotte Air Line __ 165 170 Atlanta & Gulf Cotton Mills (Georgia) __ __ __ 110 Atlanta & West Point __ __ 150 155 Atlanta Mining 17%c 17c Atlanta National Bank __ __ 290 305 Atlanta (Georgia) Trust __ __ 105 109 Atlantic City Co., pfd. __ __ *80 *85 common *10 *15 Atlantic City Gas, pfd. __ __ __ *84% Atlantic City Electric _« __ __ *100 Atlantic Coast Line 125 125 Atlantic Coast Line Co. of Connecticut __ __ 247% 255 Atlantic Cotton Mills ♦40% __ Atlantic Dock Co. __ __ __ *98 Atlantic Fruit & Steamship __ __ *1% *2% Atlantic, Gulf & West In., com __ 5% 6% preferred __ __ 10% 12 Atlantic National Bank (Providence) $60 Atlantic Power & Light — 10 shares preferred and 4 shares common sold for $1,000, March 1, 1913. Atlantic Refining ♦635 ^635 Atlantic Trust & Banking (Wilmington) __ __ 340 345 Atlas National Bank (Cincinnati) 320 325 Atlas Portland Cement, com. $60 Atlas Powder __ .. ♦gi ^92% 'Quotation nearest March 1. 1913. No quotation on that date. 1010 High Low Bid Asked Atlas Wonder Mining (Nevada) — — 12c 13c Attleborough Steam & Elec — „ — t280 Augusta-Aiken Ry. & Elec, com. __ __ 23 35 preferred — • — 75 85 Augusta & Savannah — — 103 107 Augusta Factory (Georgia) — — 30 35 Augusta Knitting Co., pfd. — — — *100 Augusta (Georgia) Savings Bank __ — 150 Augusta Southern Railroad — — — *5 Aurora, Elgin & Chicago, com — — 41 45 preferred — __ 86 891/2 Austin (Texas) National Bank — — 250 Austin State Bank (Chicago) — __ — 215 Auto Safety Razor, pfd. — __ __ *100 Auto Transportation — — *22 Automatic Electric — — — *65 Automatic Lighting — — 5% — Autosales Gum & Candy — — 27 32 Avery Co., pfd — — *96 ♦971/3 common — — — *103i/3 Babcock & Wilcox __ — 103 105 Back Bay Realty Association — __ *105 Badger State Bank (Milwaukee) — — 103 105 Bagdad Copper — — — *3i/2 Balch PubUshing, pfd. — — — *3i/2 Baldwin Locomotive, com. 49% 49l^ preferred — — 104 106 Baltimore & Ohio, com. lOlVs 100% preferred — — 83 84 Baltimore Brick, com. — — 2 2l^ preferred — — 23 25 Baltimore Electric, pfd 45 45 Baltimore Trust Co. — — "158% __ Bangor Railway & Electric, com. > — __ 88 40 preferred — — 115 120 Bank for Savings (Seattle) — — — 100 Bank of America (New York) „ — 605 615 Bank of British North America (Montreal)— __ __ 155 Bank of Buffalo — — 310 325 Bank of California (San Francisco) — 200 Bank of Charleston (South Carolina) __ — 235 240 Bank of Commerce (Cleveland) *217 Bank of Commerce (Little Rock) — __ $87l^ _- Bank of Commerce (Philadelphia) *140i/2*140i/2 Bank of Commerce & Trust (Memphis) __ __ 290 300 Bank of Commerce & Trust (Richmond) „ __ 197 200 Bank of Coney Island (Brooklyn) __ __ 135 155 Bank of Flatbush (Brooklyn) __ ._ 150 165 Bank of Hamilton (Ontario) 1 — — — 208 Bank of Manhattan County (New York) __ __ $175 $180 Bank of the Metropolis (New York) *340 *340 Bank of Montreal — — — 242 Bank of New Brunswick (St. John) — __ 275 Bank of Norfolk — — 130 140 Bank of North America (Philadelphia) *295 *295 Bank of Nova Scotia (Halifax) „ __ 26O14 261 Bank of Ohio Valley (Wheeling) __ __ $82 $85 Bank of Orleans (New Orleans) __ — 225 •Quotation nearest March 1, 1913. No quotation on thai date. f'Value" as of March 1, 1913. 1011 High Low Bank of Ottawa (Ontario) Bank of Pittsburgh Bank of Saginaw Bank of Topeka (Kansas) Bank of Toronto (Ontario) Bank of Washington Heights (New York) Bankers' Trust (Houston) Bankers Trust (New York) Bankers' Trust (St. Louis) Bankers' Trust (Tacoma) Banking Trust (Kansas City, Kan.) Banner (Colorado Springs) Banque d'Hochelaga (Montreal) Banque Nationale (Quebec) Barnard Manufacturing (Fall River) Barnett National Bank of Jackson Barney & Smith Car, com preferred Barre (Vermont) Bank & Trust Barrett Company, com. preferred (Formerly American Coal Products Co.) Barristers Hall Trust (Boston) Batavia Rubber, pfd. Bates Manufacturing Co. (Maine) *272y3 — Batopilas Mining Battery Park National Bank (New York) — Baxter National Bank (Rutland) Bay City (Michigan) Bank Bay State Gas Bay State National Bank (Lawrence) Bay State Street Ry., 1st pfd. Beacon Mfg. (New Brunswick), com < preferred Beacon Trust (Boston) Bear Creek Oil & Mining Beatrice Creamery, com. preferred Beaver Consolidated Bedford Safety Razor Bedford Trust (Boston) Beech Creek Railroad, gtd. 4% Beekman Estate, Inc., com. Begole Syndicate Belcher Mining Co. (Nevada) 20c 20c Bellows Falls Power, pfd. Bell Telephone of Canada Bell Telephone of Pennsylvania •1221/8 __ Belmont Milling (Nevada) Belmont Trust (Philadelphia) *$30 *$30 Belton Mills (South Carolina) Bergen & Lafayette Trust (Jersey City) Bergner & Engel Brewing, pfd. *95 *95 Berkeley Hotel Trust (Boston) Berks County Trust (Reading) Berkshire Cotton Mfg. (Massachusetts) Berlin (Paper) Mills (Maine) *102 Bessie Gold Dredging, com. lOVg lOVg preferred — — 11 llH *Quotatlon nearest Marcb 1, 1913. No quotation on that date. 1012 Bid Asked 210% $125 300 320 250 __ 208 275 140 141 485 495 285 125 115 120 2y8c 28/8C 159 160 140 142 75 325 12 70 82 120 87 92 100 1091/8 $90 — *100 iiVa ill/a 130 140 110 __ 200 20c 21c 175 •120 102% 1121/2 225 72i/2( ; 80c 145 151 931/^ , 95 40c 42c •100 $55 $70 *$45Vo $48 $100 iVa ; 1% ♦96 149% , 150 $7 $7 100 105 290 — $75 $85 $19* $20 235 250 High Low Bid Asked Best & Belcher Mining (Nevada) __ _- 3c 4c Bethlehem Steel, com. SeVs SSy^ preferred 66 65% Beverly Gas & Elee __ _- __ t300 Beverly National Bank (Boston) :. __ __ 152 Bibb Manufacturing (Georgia) __ __ 90 95 Big Vein Coal Co. of West Virginia __ __ *25c Bigelow Carpet *170l^ __ Bigelow -Hartford Carpet, com. 122 124 preferred — __ 118 122 Bigelow Kennard & Co., 1st pfd. *105 *105 Billings & Spencer $48 Bingham Mines 4 4^ Biograph Co. __ __ *95 Birmingham, Ensley & Bessemer R. R., pfd.__ __ __ *48% common I _« __ *16 "20 Birmingham Insurance (Pittsburgh) $100 Birmingham Railway, Light & Power, com. 100 125 ' preferred __ __ 98 102 Birmingham Trust & Savings Bank 240 250 Bishop, Babcock & Becker, com *5 preferred *70 Black Jack (Colorado Springs) __ 2c 2y8e Black Mountain Corporation 5c Blackstone Can. National Bank (Providence) __ $35 Blackstone Val. Gas & Electric, pfd. __ __ *110 Blanke (C. F.) Tea & Coffee _- __ „ "SI Blaugas Co. of America $20 Bleecker Street & Fulton Ferry __ __ 18 23 Bliss (E. W.), com. __ __ $40 $45 preferred __ __ $61 $65 Blue Bell (Colorado Springs) __ .0095c Blue Bell Mining (Nevada) 2c Blue Bull Mine (Nevada) __ 4c 5c Blue Creek Coal & Sand >. _« __ *75 Bluff City Insurance (Memphis) 93 100 Board of Trade Building Tr. (Boston) ._ »_ $101 $106 Boatmen's Bank (St. Louis) »_ __ 224y, Bob Lee (Colorado Springs) .007c Bohemia Mining 2 2*A Bon Air Coal & Iron, pfd __ __ y^ ly. Bonanza Development Co. 40c 45c Bond & Mortgage Guarantee 288 293 Bond Lumber (Mississippi) 60 Bonnie Claire Mining (Nevada) 2c Booth Fisheries, com. — — 64 65 . 1st pfd. 85 85 Booth Mills (Massachusetts) *98y8 — Booth Mining (Nevada) 5c Borden (Richard) Manufacturing „. 139 Borden's Condensed Milk Company __ __ 116 119 preferred __ _- 108 110 Border Cotton Mills (Fall River) __ >_ ._ 110 Borne-Scrymser *310 Boston & Albany __ __ __ 211 Boston Athenaeum Co *330 *330 Boston Belting 154 Boston & Chelsea Street R. R _ *75 Boston Cold Storage preferred __ __ *95 *QuotatIon nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1013 High Boston & Corbin Copper & Silver Mines Boston & Lowell Boston & Maine, common preferred Boston & Providence Boston & Worcester Electric, -common preferred Boston & Worcester Street Railway, preferred Boston Condensed Milk, first preferred Boston Duck (Massachusetts) Boston Elevated, common Boston Ely Mining Boston Gr. Rent Tr Boston Insurance Boston Land Boston Library Society Boston Manufacturing (Massachusetts) Boston Real Estate Trust Boston, Revere Beach & Lynn Boston Safe Deposit & Trust Boston Securities, preferred *31 common Boston Storage Warehouse . Boston Suburban Electric, common preferred Boston Tonopah Mining (Nevada) Bourne Mills (Fall River) 110 Bowery Bank (New York) Boylston National Bank (Boston) Braden Copper 8% Brandon Mills (South Carolina) Brazilian Traction, Light & Power Bremen Bank (St. Louis) Bridgeport Trust Co Brier Hill Steel, preferred 108 Brighton Germ. Banking (Cincinnati) Brill (J. G.) Co. preferred Brine (R. S.) Transportation Bristol Brass Bristol County National Bank (Taunton) Bristol Water British American Tobacco $23% British Columbia Copper 3% British Columbia Packers, common ^preferred "A" British North America (Bank of) Broad & Market National Bank (Newark) Broad Brook Co Broad Street Bank (Richmond) Broad Street National Bank (Trenton) 195 Broadway & Seventh Avenue Broadway Bank (St. Louis) Broadway National Bank (Nashville) Broadway Savings & Trust (Cleveland) Broadway Savings Trust (St. Louis) Broadway Trust (Camden) Broadway Trust (New York) ^Quotation nearest March 1, 1913. No quotation on that data. 1014 Low Bid Asked __ 6 7 __ 203 __ 89 91 131 __ __ 290 __ $6 $7 __ $43 $45 •120 __ •98 1300 108 108% __ 65c 70c __ $100 $103 480 500 »_ $5Vfl I $61/2 __ __ •15 110 __ $1160 __ 150 370 •31 __ *4 •10 __ $112 __ $71/2 1 __ $65 $68 — Ic 2c ~~ 425 "■" 120 125 8% __ __ 85 __ 96ys 1 96% 650 ~ 157 — '_'_ 320 325 *100 •102 *60 •75 $391/4 $40% 103 •135 $233/8 3^8 148 154 __ 154 __ 155 155 __ $18 __ $60 195 __ 170 182 135 — __ 150 155 __ •235 __ __ 155 194 __ __ 165 175 High Low Bid Asked Brockton Gas Light ^___^__^ __ __ __ fi70 Bromfield Building Trust (Boston) __ __ __ $95 Bronx National Bank (New York) __ __ *200 Bronze Metal, preferred __ __ __ *85 common ^ *60 *65 Brooklyn Academy of Music __ *22i4 Brooklyn City R. R >_ __ $16 $16l^ Brooklyn Factory & Power, preferred *100 Brooklyn Rapid Transit 89l^ 89 Brooklyn (New York) Trust Co __ __ 495 605 Brooklyn Union Gas __ __ 130 ISS^i Brooklyn Warehouse & Storage *67V^ Brown Hoisting Machinery, preferred "93 Brown Shoe, common __ 50 54 preferred __ 92 94 Brunswick-Balke-ColL, preferred __ IO914 110l^ Brunswick Cons. Gold Min. (California) __ __ 80c 90c Brunswick Terminal & Railway Sec 8% 8% Bryant Park Bank (New York) __ __ 150 Bronx Borough Bank (New York) __ «_ 300 Bronx National Bank (New York) _- — 180 195 Bryant Paper, common __ *16% Buckeye Pipe Line __ __ $82 $83 Buck's Stove & Range, preferred __ 101 Bucyrus Co, preferred __ __ *76 *83% Buffalo & Susquehanna R. R., preferred __ _> *1 Buffalo Citj^ Gas, preferred 15 common . — — 5 6 Buffalo General Electric __ __ __ 1031^ Buffalo Loan, Tr. & Safe Dep. Co _- __ 125 128 Buffalo Mines _. — 2l^ 21/3 Buffalo, Rochester & Pittsburgh, common 105 115 preferred — __ 123 150 Bullion Mining (Nevada) — — — 2c Bunker Hill Mining (California) __ — $1.80 Burke Electric Co *20 Burl., Cedar Rapids & Nor _. __ __ *127ya Burlington (Iowa) Savings Bank — — 125 Burroughs Adding Machine 347 357^ Burt (F. N.) Co., common. __ »» __ 100 preferred — 104 Burton Dry Goods, preferred *100 *100 Bush Terminal, com __ — *54 *60 Business Real Estate Trust (Boston) __ __ __ $97 Butch. & Drov. National Bank (New York)— __ __ *$32ya*$35 Butler (James), pfd — — *65 Butler (Jim) Tonopah Mining (Nevada) >_ __ 73c 75c Butler Mill (New Bedford) — — — 130 Butte & London Copper Dev — — 25c 30c Butte & New York I14 1^4 Butte & Superior Copper — — 31^4 31% Butte-Ballaklava Copper — — 2% 2% Butte Central Copper — — 8:^ Si/g Butte Coalition Mines (old stock) — — *15 Butterick Co. — — 28 31 By-Products Coke Corporation — — — *130 *Quotatlon nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1015 High Low Bid Asked Cabarrus Cotton Mills (North Carolina) — — 130 140 Cabot Manufacturing (Maine) *120 Cactus Copper — — 6c 7c Calaveras Copper — — 2H SVa Caledonia Mining (Nevada) 85c 85c California Electric Generating, pfd __ — 75 80 California Fruit Canners Association — — HSVa — California-Idaho Co., Series A — — — *50 California Insurance (San Francisco) __ — $73 California Midway Oil — — 10%c Ic California Petroleum, com 50% 491/3 preferred — — 80 82 California Portland Cement — — 110 California Railway & Power, prior pfd __ __ 871/2 QSVa California Sav. & Com. Bank (Los Angeles)— __ __ 190 California Street Railway __ — I241/2 __ California Wine Association, com — __ 46l^ __ preferred — — 83% 8514 Calumet & Arizona Mining — — 62 6214 Calumet & Chicago Canal & Dock __ — 53 57 Calumet & Hecla Mining _.. — 455 460 Calumet-Corbin — — 5c 10c Calumet National Bank — — 140 150 Calvert Bank (Baltimore) — — $70 Camaguey Co., Ltd , __ __ — *65 Cambria Iron — $44 $45 Cambria Steel — — $51 $511/2 Cambridge Electric Light __ __ __ 1305 Cambridge Electric Securities t305 Cambridge Gas Light ., 285 285 Camden & Burlin^on County Railroad __ __ $321/2 $36i4 Camden & Suburban __ __ $19 $20 Camden (New Jersey) National Bank 191 Camden (New Jersey) Safe Deposit & Trust- *100 *100 Canada Bread, com __ __ 29 31 Canada Brick & Fire Proofing, pfd "100 *100 Canada Cement, com __ _- 27% 28 preferred __ __ 91 91% Canada Foundries & Forgings, pfd *100 Canada Interlake Line, com 69 preferred >_ 87% — Canada Landed & National Investment *170 Canada Life Assurance *170 Canada Machinery __ __ 591/2 61 Canada North-West Land *99 Canada Permanent I961/2 Canada Southern 60 63 Canadian Bank of Commerce (Toronto) __ __ $110 Canadian Car & Foundry, com __ __ 77 80 preferred 116 115 Canadian Cereal & Flour Mills *45 *45 Canadian Consolidated Rubber, com __ __ 85 90 preferred _^ 98% 99 Canadian Converters 46 47 Canadian Cottons, com __ __ 42% 43 preferred __ __ 78 78% Canadian General Electric, com __ __ 110 Canadian Locomotive, com 67 preferred __ __ __ 95 •Quotation nearest March 1, 1913. No quotation on tiiat date. f'Value" as of March 1, 1913. 1016 High Low Bid Asked Canadian Marconi — ~ SVg 41/2 Canadian Pacific, com — 2311/2 231l^ . preferred — — 97 99 Canadian Salt __— *120 Canadian Venezuelan Ore, Ltd _ *36 *36 Canal-Louisiana Bank & Trust (New Orleans) __ __ 105 Canal National Bank (Portland, Me.) — __ 108 110 Caney River Gas *$32 *$32 Canton Co. — — 136 Canton National Bank (Baltimore) __ — 105 110 Capital National Bank (St. Paul) __ „ 137 Capital National Bank (Washington) 224 Capital Traction — __ 122% 1231/, Capital Trust (St. Paul) __ — 145 Carbolite Co. __ __ *3i/a __ Cardenas American Sugar, pfd — lOOVa 101% Caribou Oil __ — __ $1 Carolina Power & Light, pfd __ __ *93 *100 ■ common __ 26 28 Carolina Savings Bank (Charleston) __ __ 225 250 Carriage Factories, Ltd., pfd __ __ $100 Casco National Bank (Portland, Me.) __ __ 105 106 Case, Lockwood & Brainard 155 Case (J. L) Thresh. Mach. pfd. stk. tr. ctfs __ _- 100% 102l^ Casein Co. of America, com 8 preferred 40 Cash Boy Consolidated Mining (Nevada) __ __ 8c 10c Cass Avenue Bank (St. Louis) 200 Casualty Co. of America __ 110 120 Catawissa Railroad 1st pfd __ __ $55 $55i/, 2d preferred __ __ $531/2 $54i/, Cayuga & Susquehanna ($30 par) __ 200 215 Celluloid Co. __ __ 135 138 Centennial Copper Mining __ __ 14% 16 Centennial National Bank (Philadelphia) *275 *275 Center Creek Mining __ __ $1.50 Central Aguirre Sugar, com *62 Central Arkansas Railway & Light, pfd *100 *100 Central Bank (Rochester) __ __ 240 250 Central Bank & Trust (Atlanta) >_ __ 140 143 Central Building Trust (Boston) __ __ __ $90 Central Canada Loan & Savings *190 Central Coal & Coke, com __ __ 92 93 preferred __ __ sii/a 8314 Central Crosstown Street Railway __ __ __ 10 Central-Eureka Mining (California) 15c 14c Central Fire Works, com __ __ 2 3 preferred __ __ 25 30 Central Georgia Power __ __ *34 Central Leather, com 28% 2814 preferred 96l^ 9&y^ " _I Central Maine Power, pfd __ __ *94 common __ __ *25 Central Manufacturing Dis. Bank, (Chicago). __ __ 140 150 Central Massachusetts Light & Power, pfd *105 *105 Central Mass. Power, pfd __ __ __ fiio Central Mexico Light & Power, pfd _I II 64 68 Central National Bank (Buffalo) __ __ 200 Central National Bank (Cleveland) __ __ 163 II ^Quotation nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1017 High Low Bid Asked Central National Bank (Columbus, 0.) __ — — 103 Central National Bank (Frederick) -_ __ $35 Central National Bank (Los Angeles) -_ — 219 226 Central National Bank (Oakland) __ __ 160 Central National Bank (Philadelphia) *440 ^440 Central National Bk. of Richmond (Virginia) _- — 144 147 Central National Bank (St. Louis) __ — 118 120 Central National Bank (Topeka) >_ __ — 151 Central National Bank (Wilmington, Del.) — __ __ 115 125 Central National Bank (York) — __ 99 102 Central Oil 1.10 Central of New Jersey — — 345 350 Central Park, North & East River __ .._ 13 Central Savings Bank, Detroit __ __ 213 220 Central & South American Telegraph __ __ 105 112 Central State Bank & Trust (Memphis) __ __ 215 220 Central States Electric, pfd — __ *89 Central Syndicate Building Co -_ __ — *100 Central Trust (Altoona) __ — 200 210 Central Trust (Camden) _- __ __ lOSi/g Central Trust (Harrisburg) __ >_ $65 $70 Central Trust (Indianapolis) __ __ 110 120 Central Trust (Macon) . __ __ 90 95 Central Trust (New York) __ — 1015 1030 Central Trust (San Antonio) __ 125 Central Trust Co. of Illinois (Chicago) __ __ 234 237 Central Trust & Safe Deposit (Cincinnati)™ __ __ 290 310 Central Trust & Savings (Philadelphia) *$65 *$65 Centre Wheeling Savings Bank (Wheeling) __ 215 Century Bank (New York) __ __ 220 230 Chace Mills (Fall River) __ __ __ 115 Challenge Mining (Nevada) __ __ 3c 5c Chalmers Motor Co., pfd *102y2 $1021/3 common __ _« *132 Champion Coated Paper, com. 180 preferred __ __ 110 II21/2 Chapin National Bank (Springfield, Mass.) __ 115 120 Chapin-Sacks __ __ 160 220 Chapman National Bank (Portland, Me.) __ __ 108 110 Charleston (South Carolina) Savings Inst'n__ __ 425 450 Charlestown Gas & Elec __ __ __ tl30 Charlotte (North Carolina) National Bank __ 155 Charter Oak National Bank (Hartford) 155 Chase National Bank (New York) __ __ *690 715 Chatham Bank (Savannah) __ __ 138 Chatham & Phoenix National Bk. (New York) __ __ $44 $451^ Chelsea Exchange Bank (New York) __ __ 150 153 Chelten Trust (Philadelphia) *$75 *$75 Chemical National Bank (New York) __ *440 448 Chemung Canal Trust (Elmira) __ __ 180 190 Cherokee Copper 1 Chesapeake & Ohio 73% 73% Chesebrough Manufacturing __ __ $332^4 $337Vi Chicago & Alton, com __ 10 20 preferred __ __ 251/2 40 Chicago Auditoriimi __ __ 15 16 Chicago Brewing & Malting, com __ __ 1 1% preferred __ __ 6 Sy^ Chicago, Burlington & Quincy _> __ ♦209 217 •Quotation nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1018 Bid A8k( 275 150 170 45 49 100 103 30 35 93 94 ♦62 *68 167 168 1041/3 •58 *59 High Low Chicago City Bank & Trust (Chicago) Chicago City Railway Chicago & Eastern Illinois, com preferred Chicago Elevated Railways, com < preferred Chicago Great Western, com 15 15 Chicago, Indianapolis & Louisville, pfd Chicago Jctn. Ry.& Un. Stk. Yds. (stp'd stk.) preferred Chicago Lumber & Coal Central Mexico & Southern Pacific, com 109 lOSVg ^pref erred :. ISSi/g ISSVa Chicago-New York Air Line — — — *3V3 Chicago & North Western, com 136% 136^4 ■ preferred Chicago Pneumatic Tool Chicago Railways Certificates "1" 931/3 921/3 ■ "3" 233/4 233^ "3" «4» Chicago Railways Equipment Chicago R. E. Trustees Chicago, Rock Island & Paciffic Ry. Chicago, St. Paul, Minneapolis & Omaha, com. preferred Chicago Savings Bank & Trust (Chicago) Chicago Securities Co., pfd. *100 *100 Chicago Suburban Gas & Electric, pfd Chicago, Terre Haute & S. E Chicago Title & Trust Chicago Union Traction, stpd. Chicago Utilities, com preferred Chicago, Wilra. & Vermilion Cont Chicopee Manufacturing (Massachusetts) *110 Chicopee National Bank (Springfield, Mass.) Chief Consolidated Mining Chihuahua & Sinaloa Development Childs Co., pfd. common Chino Copper $38% $37i/2 Chippewa Bank (St. Louis) Chollar Mining (Nevada) Christopher & 10th Streets Railroad Cigar Machine Corporation of America Cincinnati & Hamilton Traction, com. ■ preferred Cin. & Sub. Bell Telephone Cincinnati, Dayton & Toledo Tr., com Cincinnati Gas & Electric Cincinnati Gas Trans. Cinn. N. O. & Tex. Pac, com preferred Cinn., Newp. & Cov. Lt. & Tr., com. preferred Cincinnati Northern Cincinnati, Sandusky & Cleveland, pfd. Cincinnati Street Railway •Quotation nearest March 1, 1913. No quotation on that date. 1019 180 190 491/3 50 '6% "71/* 3% 4 851/3 < 5975 *100 110 125 130 140 155 147 151 "— *97i/. 15 25 204 205 *6i/3 21/0 3% *6 *12 *30 *42i/3 185 190 1% 1% *1 *110i/3 *113 *150 ' *162 215 " Ic 125 135 *iy4 *ll/3 751/4 105 $1071/3 $110 23 25 85 115 255 1071/3 88I/4 93 763/4 821/3 35 50 *$67i/3 $721/3 H *$56i/3 High Low Bid Asked Cincinnati Tobacco Warehouse __ __ __ 60 Cincinnati Union Stock Yards __ __ __ lOO Cities Service, pfd. __ __ 88 90 common __ __ 140 145 Citizens' Bank (Buffalo) __ __ 225 Citizens* Bank (Norfolk) __ __ 275 Citizens' Bank & Trust (Memphis) _» __ 140 150 Citizens' Bk. & Tr. Co. of La. (New Orleans) __ _» 120 123 Citizens' Central National Bank (New York) __ __ *197 203 Citizens' Deposit & Trust (Allentown) __ __ $50 $51 Citizens' Firt Insurance of Baltimore __ __ __ *85 Citizens' National Bank (Baltimore) __ __ 42 42ya Citizens' National Bank (Cincinnati) __ 203 210 Citizens' National Bank (Covington) __ __ 160 Citizens' National Bank ( Fredericksburg) ___ __ __ 450 Citizens' National Bank (Los Angeles) __ __ 260 265 Citizens' National Bank (Louisville) __ 250 255 Citizens' National Bank (Macon) __ __ 120 123 Citizens' National Bank (Raleigh) __ __ 160 Citizens' National Bank (Waterbury) __ __ 140 150 Citizens' Passenger Railway (Philadelphia)— __ __ $138' $143 Citizens' Savings Bank (Washington) __ __ $19^^ — Citizens' Savings & Trust (Cleveland) *265 Citizens' Telephone, pfd. 30^4 Citizens' Traction (Pittsburgh) __ __ $50 $55 Citizens' Trust (Brooklyn) __ __ 150 155 Citizens' Trust (Paterson) __ __ 220 Citizens' Trust Co. (Savannah) __ 140 Citizens' Trust (Utica) __ __ 225 230 Citizens' Trust & Savings (Columbus, Ohio) __ __ 100 110 City & Suburban Homes *99 City Assoc. (Boston) __ __ $540 $580 City Bank of Hartford __ __ 125 City Bank of New Haven __ __ 135 City Bank (York) __ __ $95 $100 City Bany & Trust (Hartford) __ __ 125 City Bank & Trust (New Orleans) __ __ 114 City Dairy, com. __ __ 50 — preferred 100 City Hall Bank (Cincinnati) __ __ 300 City Ice Delivery __ __ *75 *102 City Investing, com. 43 48 preferred — — 100 101 City Insurance (Pittsburgh) *$75 *$75 City Manufacturing (New Bedford) __ 115 120 City National Bank (Bridpeport) __ __ 215 City National Bank (Columbus, Ohio) __ __ 130 135 City National Bank (Dallas) __ __ 350 360 City National Bank (Dayton) __ __ 3OO 310 City National Bank (Duluth) __ __ 130 City National Bank (Galveston) __ __ 200 210 City National Bank (Holyoke) __ __ 113 114 City National Bank (McAlester) __ __ __ 160 City National Bank (Omaha) __ __ 105 112 City National Bank (San Antonio) >_ __ 225 City of New York Insurance __ __ 165 185 City Passenger Railway (Reading) __ __ $138 $143 City Railway (Dayton, 0.), com. __ __ __ 17O preferred __ _> 145 150 ♦Quotation nearest March 1, 1913. No quotation on that date. 1030 Bid Asked $850 125 __ 185 3%c lie *80 *85 *85 *88 *88 *91 165 107 *$8iy2 *$47y2 *83 $49y2 8 *30 — *5y3 *30 53 57 90 95 400 Higli Low City R. E. Tr. (Chicago) City Safe Deposit (Albany) City Trust (Newark) C. K. & N. (Colorado Springs) Claflin (H. B.) Co., com 1st preferred 2nd preferred Claremont Bank (Jersey City) Clark Avenue Savings Bank (Cleveland) Claverly Trust (Cam.) — __ __ $410 Clement National Bank (Rutland) __ __ 250 Clements Hotel Co., com. __ — __ $100 Cleveland -Akron Bag *148 Cleveland & Buffalo Transit *140 Cleveland & Pittsburgh, gtd. special guaranteed betterment Cleveland & Sandusky Brew., com. preferred Cleveland & South Western Traction, com. preferred Cleveland, Cincinnati, Chicago & St. L., com. ■ preferred Cleveland Cliffs Iron Cleveland Electric Illuminating __ __ *134% Cleveland National Bank *106y8 __ Cleveland, Painesville & Eastern 5 20 Cleveland Railway 103% __ Cleveland, Southwest & Columbus Ry., com preferred Cleveland Stone *110 Cleveland Trust Co. Cleveland Union Stock Yards Cleveland Worsted Mills Cliff Mining Clifton Manufacturing (South Carolina) Clinchfield Coal Corporation Clinton Cotton Mills (South Carolina) Clinton Trust (Newark) Cluett Peabody, com. • preferred Coal & Iron National Bank (New York) Coal Land Securities Coal Valley Land Co. Coalinga Central Oil Coalinga National Oil Cobalt Silver Queen C. 0. D. Consolidated 7c 7c Collins Co. (Connecticut) Colonial Bank (New York) Colonial Beach Co. *25 Colonial Oil Colonial Trust (Baltimore) Colonial Trust (Philadelphia) *$100 *$100 Colonial Trust (Pittsburgh) *$179 *$179 Colonial Trust (Reading) Colonial Trust (Waterbury) Colonial Trust & Savings Bank (Chicago) — Colonial Savings & Loan (Can.), pfd *80ya „ Colwell Lead, pfd. __ — *70 *87 •Quotation nearest March 1, 1913. No quotation on tiiat date. 1031 sy^ ~ 30 232y2 235 135 125 1% 4 95 *77 115 125 150 60 63 98 101 160 165 *47 *40 *46 20c 16c 25c 4c 6c 205 215 425 — 130 135 $28% $29y3 $16 $17 160 223 228 High Low Bid Asked Colorado Yule Marble, 2d pfd. __ __ ♦121/2 _. Colt's Patent Fire Arms Mfg. (par $100) __ __ 178 182 Colorado & Southern, com. 26 26 1st preferred __ __ 67 69 2nd preferred __ __ 60 b7 Colorado Fuel & Iron, com. 33% 33% preferred 170 177 Colorado Gold Camp (Colorado Springs) — — .005 Colorado Metals Extraction Co. '3U Colorado Power, com. 20 preferred 75 Columbia Avenue Trust (Philadelphia) *170 *170 Columbia Bank (New York) __ __ •330 340 Columbia Bank & Savings (Cincinnati) 450 500 Columbia Gas & Electric __ __ 13^4 15 Columbia-Knickerbocker Trust (New York) 540 650 Columbia Mountain Mining (Nevada) Ic 2e Columbia National Bank (Buffalo) __ __ 300 350 Columbia National Bank (Washington) __ __ 250 268 Columbia National Life Insurance (Boston)— __ __ 120 125 Columbia Oil __ __ 79c Columbia (S. C.) By., Gas. & Electric, com__ __ __ 50 ^preferred __ __ 85 95 Columbia Sugar __ __ 8 10 Columbia Title (Washington) __ __ SeVg __ Columbia Trust (Boston) __ __ 120 Columbus Dental Mfg., pfd. __ __ 114l^ __ Columbus Edison, pfd. __ __ 103 common 851/2 Columbus Forge & Iron, pfd. __ __ __ 100 Columbus Gas & Fuel, com. __ __ 37 • preferred 70 Columbus Light, Heat & Power, pfd. __ __ __ 9514 common __ __ 54% __ Columbus, Newark & Zanesville 100% Columbus Railway, pfd. __ __ __ 90*4 ■ common. __ 69% 70% Columbus Railway & Light ($20 paid) __ __ 18 191/2 Columbus & Xenia Railway $101 Combination Fracticn (Nevada) 8c 8c Commerce & Savings Bank (Washington) I21/2 17 Commerce & Trusts (Richmond) 197 Commerce (Bank of), Can. __ __ __ 219% Commerce (National Bank of New York) __ _« 191 193V3 Commerce Insurance (Albany) $42^2 Commerce Trust Co. (Kansas City, Mo.) __ __ 227 2281/2 Commercial Bank (Bay City) __ __ 225 250 Commercial Bank (Harrisburg) $80 Commercial Bank (Jacksonville) 100 Commercial Bank (Savannah) __ __ 116 Commercial Bank of Wheeling __ __ ' __ 225 Com'l-Germania Tr. & Sav. Bk. (New Orl.)__ __ __ 235 Commercial National Bank (Boston) 165 170 Commercial National Bank (Charlotte) 159 160 Commercial National Bank (Columbus, Ohio) 240 260 Commercial Nat'l Bank (Kansas City, Kan.) __ __ 275 Commercial Nat'l Bank (Kansas City, Mo..) __ 240 Commercial National Bank (Los Angeles) 175 205 Commercial National Bank (Macon) __ 120 123 •Quotation nearest Marcfa 1, 1913. No quotation on that date. 1033 High Low Bid Asked Commercial National Bank (Minneapolis) __ — 110 126 Commercial National Bank (Musk.) __ __ 150 Commercial National Bank (New Orleans) 285 Commercial National Bank (Raleigh) 130 Commercial National Bank (Saginaw) __. __ 225 230 Commercial National Bank (Shreveport) 290 300 Commercial National Bank (Washington)— _-_ __ 200 205 Commercial Savings Bank (Charleston) __ 125 130 Commercial Savings Bank (Grand Rapids)— — — 200 201 Commercial Savings Bank & Trust (Toledo) __ — 100 Commercial Trust Co. of N. J. (Jersey City) __ __ 370 380 Commercial Trust (New York) — — 93 97 Commercial Trust (Philadelphia) *435 *435 Commercial Trust (Reading) __ __ 100 110 Commercial Trust & Sav. Bank (Memphis) 375 Commercial Union — __ $241/2 $271/3 Commonwealth Bank (Baltimore) __ $90 Commonwealth Bank (Richmond) 115 120 Commonwealth Edison — __ 140 141 Commonwealth Gas & Elec, pfd __ __ __ tl04 Commonwealth Insurance (New York) 325 Commonwealth National Bank (Dallas) __ — 185 190 Commonwealth National Bank (Kansas City) *245 Commonwealth Power, Ry. & Light, com __ „ 68 70 ■ prefen-ed __ __ 891/3 90i/a Commonwealth Title Ins. & Tr. (Phila.) *238 *238 Commonwealth Trust (Boston) __ __ 205 210 Commonwealth Trust Co. (Buffalo) __ __ 200 205 Commonwealth Trust (Harrisburg) __ __ 350 400 Commonwealth Trust (Pittsburgh) __ — 172 176 Commonwealth Trust (St. Louis) — — 92 • 93 Comp.-Tab.-Rec. __ __ 431/3 451/3 Comstock Stock *10 *9 Comstock Tunnel *8c Concord & Montreal, class 1 *135 class 2 *135 class 3 — — 135 class 4 *131 *130 Concord & Portsmouth 175 Conestoga National Bank (Lane.) __ __ 380 Coney Island & Brooklyn Railroad — __ 98 101 Confederation Life Assurance *300 Confidence Mining (Nevada) __ __ 31c Congress Hotel, com. __ 97 101 preferred __ __ 62 67 Congress St. Assoc. (Boston) __ __ $100 $102 Congress St. Bldg Tr. (Boston) __ __ __ $65 Coniagas Mines 8.00 Conley Foil — __ 290 300 Conn. & Pass. Rivers, pfd. __ __ __ 126 Connecticut Fire Insurance (Hartford) __ __ 350 360 Connecticut Footwear, pfd. *10 common __ *6 Connecticut General Life Insur. (Hartford)— __ __ 500 Connecticut Insurance (Hartford) __ __ 350 360 Connecticut National Bank (Bridgeport) 205 Connecticut Power, pfd. __ __ __ *92i/3 Connecticut Railway & Lighting, com. — __ *72 *75 preferred — — *75 *80 •Quotation nearest March 1, 1913. No quotation on that date. t"Value" as of March 1, 1913. 1023 High Low Bid Asked Connecticut Rirer Banking (Hartford) — — $85 Connecticut River Power, com — — — *^^Vz Connecticut River Railroad — — — 260 Connnecticut Trust & Safe Dep. (Hartford) __ __ 312 318 Conqueror Consolidated Mining (Nevada) __ — — 2c Consolidated Arizona Smelting — — 30c 40c Consolidated Car Heating — — 70 80 Consolidated Coal of Maryland — — 100 Consolidated Coal Co. of St. Louis — — — 20 Consolidated Fire Works, com. — — 2 preferred — — 25 30 Consolidated Gas (New York) 1321/8 1311/2 Consolidated Gas of Pittsburgh, pfd *$24 *$22y3 Consolidated Gas Elec. & Power of Bait., com. __ __ 1121/2 115% preferred — — 115 119 Consolidated Ice (Pittsburgh), com. „ — $81/3 $91/, preferred — — — $48 Consolidated Imperial Mining (Nevada) — — Ic 2c Consolidated Lumber, pfd. — — — *100 Consolidated Mercury Gold Mining — — 2c 4c Consolidated Realty — — — .IO81/3 Consolidated Rubber Tire, com. — — 19 21 preferred — — 75 80 Consolidated Telephone of Buffalo — — 9 10 Consolidated Traction Co. of New Jersey __ __ * 73 1/2 — Consolidated Virginia Mining (Nevada) 18c 18c Constitution Wharf Tr. (Boston) — — — $104 Consumers Gas (Toronto) — — — $92% Consumers Power (Michigan), pfd — — 921/2 95 common — — 6.31% basis Contact Copper — — 20c 25c Continental Bank & Trust (Ft. Worth) __ — 125 145 Continental Bank & Trust (Shreveport) __ __ — $126 Continental Can, com. — — 50 54 preferred — — 91 941/9 Cont. & Com'l National Bank (Chicago) __ — 312 314 Continental Equit. Title & Tr. (Phila.) *$100i/a *$100% „ Continental Insurance (New York) — — 940 960 Continental Mills (Maine) ^95 Continental National Bank (Indianapolis)— __ __ 120 Continental National Bank (Salt Lake City)- __ „ 145 146 Continental Oil — — *1800 *1900 Continental Passenger Railway •$1231/3 __ Continental Trust (Baltimore) — — 215 218 Continental Trust (Macon) __ — 105 IW Contoocook Mills (New Haven) — — — *104 Conveyancers' Title Insurance (Boston) — — 100 Copley Square Trust (Boston), com __ — -- $45 preferred ~ — -- $100 Copper Range Consolidated Co. — — 451/3 46 Corbin Copper — — 69c 70c Corby (H.) Distillery, pfd. *98 *98 Corcoran Insurance (Washington) — -- $80 Corn Belt Bank (Kansas City, Mo.) — — 150 Corn Exchange Bank (New York) — — *320 *325 Corn Exchange National Bank (Chicago) __ — 417 420 Corn Exchange National Bank (Omaha) __ — 100 110 Corn Exchange National Bank (Philadelphia) ^300 *300 •Quotation nearest March 1, 1913. No quotation on that date. 1024 High Low Bid Asked Corn Products Ref., com. 12Vi 12 preferred 70 CTVa Cornell Anthracite Mining — — *143ya*150 Cornell Mills (Fall River) — — — 175 Cortez Associated Mines — — 30c 40c Coshocton Light & Heat, pfd. — — — 100 common — — 32 40 Cosmopolitan Bank & Savings (Cincinnati)— — — $70 County Fire Insurance (Philadelphia) $125 County Savings Bank (Scranton) __ — 4371/3 442ya Courtenay Manufacturing (South Carolina)— — — — 95 Covington (Kentucky) Sav. Bk. & Tr — — 140 150 Cox Multi Mailer — — — *2>y^ Cracker Jack Mining (Nevada) — — — Ic Cramp (Wm.) & Sons Ship & Eng. Bldg. Co. — — 17 25 Creamery Piackage — — 95 97 Crescent City S. Y. & S. H — — $221/3 — Crescent Pipe Line — — $61 $63 Crex Carpet — — 75 85 Cripple Creek Central, com. — — *35 *43 preferred *45 *50 Cripple Creek Consol. (Colorado Springs) — — IV^c 2c Crocker-Wheeler, pfd. — — — *105ya common — — — *80 Crowell Publishing, com. — — — *200 preferred — — *99y3 „ Crown Point Gold & Silver Mining (Nevada) — — 20c Crown Reserve Mining — — 3% 4% Crows Nest Pass Coal *70 Crucible Steel, com. — — *153/4 *15% preferred — — *92 *93 Cuba Railroad Co., pfd. — — 94 Cuban-American Sugar, com. — — — 40 preferred — — — 92 Cumberland Co. (Me.) Pow. & Lt., com — — 60 60 preferred — — 96 96% Cumberland Corporation, pfd — — — *50 common — — — *13 Cumberland Pipe Line — — — *82y, Cumberland Tel. & Tel. *127 Cumberland Val. Nat. Bank (Nashville)— — — 100 103 Curtice Bros., pfd. — — 115 common — — 161 Cuyahoga Telephone, com — — — $14^/^ preferred $38% — Dacust Realty — — '65 Dallas Electric, com. „ — 60 61 1st preferred — — 94 96 2nd preferred — — 74 76 Dallas Manufacturing (Alabama) — — 100 110 Dallas Trust & Savings Bank — — 175 180 Daly -West Mining — — Zy% 4 Dan Patch Electric Railway — — — *65 Dante (Colorado Springs) — — 2V4c 2%c Darlington Manufacturing (South Carolina) — — — 45 Dartmouth Mfg. (New Bedford), com. — — — 240 preferred — — 103y3 — Dauphin Deposit & Trust — — 280 *QuotatIon nearest March 1, 1913. No quotation on that date. 1025 High Davenport (Iowa) Savings Bank Davis-Daly Copper Davis Mills (Fall River) Davol Mills (Fall River) Dayton & Michigan, com. preferred Dayton & Western Tr., com. preferred Dayton Brewing, com. *8l^ preferred Dayton (Ohio) National Bank Dayton Power & Light, com, preferred Dayton (Ohio) Savings & Trust De Long Hook & Eye 91 De Luxe Oil Dedham & Hyde Pk. Gas & Elec. Light Deere & Co., pfd. Delaware Railroad Delaware & Bound Brook, gtd. Delaware & Hudson ISOVg Delaware Insurance (Philadelphia) *$7V3 Delaware, Lackawanna & Western- Delaware, Lackawanna & Western Coal Delaware Trust (Wilmington) Delevan Condensed Milk *10 Delta Building Trust (Boston) Demerara Electric, com Denholm & McKay, pfd Denver & Northwestern Railway Denver & Rio Grande, com preferred Denver Gas & Electric Denver Union Water, com preferred Deseret National Bank (Salt Lake City) Deseret Savings Bank (Salt Lake City) Des Moines & Fort Dodge, preferred common Detroit & Cleveland Navigation Detroit & Mackinac, com. preferred Detroit Creamery Co Detroit Edison Detroit Fire & Marine Insurance Co Detroit, Hillsdale & Southwestern, gtd Detroit Iron & Steel, com ^preferred Detroit Savings Bank Detroit, Toledo & Ironton, 1st pfd 2d preferred Detroit Trust Co Detroit United Detroit United Bank, Ltd Devonshire Building Trust (Boston) Dexter Horton National Bank (Seattle) Dexter-Union Mines (Nevada) 4c Dexter White Caps (Nevada) 8c Dial Cash Register *QuotatlOD nearest March 1, 1913. No quotation on that date. 1026 Low Bid Asked 305 315 UVs $1A - 1021/3 - 921/3 $39 $42 $933/4 __ — 100 ~ 100 107 II II 30 160 165 25 261/2 — *82 *85 ~ 210 II 60c -I __ "$55 98 98% $433/4 $461/4 .60V, 188 193 $1971/2 $2071/2 $155 $170 160 210 10 — $85 _„ -_ *80 - •102 __ 108 113 191/2 21 34 361/3 20 22 31 34 31 34 325 327 1114 1115 *20 *25 *4 *7 1021/2 1031/2 105 100 23 24 1151/2 120 __ $130 *92 '95 91/4 10 __ 300 — 10 4 327 334 " 76 85 2071/3 — -_ $55 310 325 4c 8c High Low Bid Asked Diamond B. B *3 *3 Diamond Match 104% 1045/3 Diamondfield Blk. Butte Reorg. Min. (Nevada) __ __ 2c 3c Diamondfield Daisy Gold Mining (Nevada) 4c 4c Dime Deposits Bank ( Wilkes -Barre) __ __ $103 $105 Dime Deposits & Discount Bank (R'd'g) __ __ $450 $460 Dime Savings Bank (Detroit) __ __ 234 Dime Savings Bank (Toledo) __ — $141 Diamond (L.) & Sons, pfd — — — *100 Distillers' Securities Corp — — 18 18l^ District National Bank (Washington) __ __ 1471/2 150 District of Columbia Paper Manufacturing — __ 134 Dixon (Joseph) Crucible — — 300 325 Dr. Jack Pot — — 51/40 6l^c Doe Run Lead ._ — $65 $70 Dollar Savings & Trust (Wheeling) __ __ 251 257 Dome Mines, Ltd __ __ *17y2 — Domestic Bank & Tile, pfd __ __ __ *100 Dominion Bank (Canada) — — $112% $1121/2 Dominion Canners, com — 75% 80 preferred __ __ __ 102 Dominion Coal, pfd — — 110 112 Dominion Iron & Steel, pfd 102 Dominion Life Assurance __ — *200 Dominion Mahogany & Veneer, pfd *65 *65 Dominion Permanent Loan — — — *83 Dominion Savings & Investment *78 Dominion Steel, com 531^ 53% Dominion Steel, pfd. — 103 Dominion Telegraph __ — $50 Dominion Textile, Ltd., com 85 85l^ preferred 103 Dominion Trust Co., Ltd *115 *115 Donald Steamship __ __ *62 Dorchester Electric *8% *8% Dorchester Trust (Boston) __ 110 Doten-Dunton Desk Co., pfd __ __ — *100 Douglas (W. L.) Shoe, pfd __ __ *91 Dow Chemical __ __ 6% 7 Draper Co. (Me.), com __ __ 235 245 Drexel State Bank (Chicago) __ 200 205 Driver-Harris Wire *100 Drovers' & Mechanics' Nat'l Bk. (Baltimore). __ __ 210 225 Drovers' & Mechanics' National Bank (York) __ __ 190 195 Drovers' Deposits National Bank (Chicago)— __ __ 242 247 Drovers' National Bank (Kansas City, Mo.)__ __ __ 165 Drovers' Trust & Savings Bank (Chicago)™ __ __ 250 duPont (E. I.) deNemours, com 185 preferred __ 90 95 duPont International Powder, pfd __ __ __ *70 duPont Powder, pfd _. __ *93i/2 *94i/3 common __ __ *130 *133 Duluth Edison Electric, com __ __ 72 76 preferred __ __ __ 25 Duluth, South Shore & Atlantic, com __ _« 5l^ 8 preferred __ __ 13 15 Duluth Superior Traction, com __ __ *70 *73 preferred __ __ *63 *70 Dunnellon Phosphate Co __ __ __ *50 •Quotation nearest March 1, 1913. No quotation on that date. 1027 High Low Bid Asked Dunton Desk, pfd — - — *102 Duquesne National Bank (Pittsburgh) •$240 *$240 Durfee Safe Deposit & Trust (Fall River) — — „ 200 Durkee (Charles D.) — - — *10 *12i/8 Dwelling House Association (Boston) — — — $750 Dwight Manufacturing (Massachusetts) *1175 Eagle & Blue Bell Mining __ __ 1 1^^ Eagle & Phenix Mills (Georgia) — >- 75 80 Eagle Lock — — $50 $55 East Boston Land — — $121/2 $14 East Butte Copper Mining — — 121/3 12% East Canada Fisheries, pfd *15 *15 East Canada P. & P *5 East End Bank (Cincinnati) — — 115 120 East End Bank (Erie) — _> $100 $102 East Reading Electric Railways — — $75 $80 East River National Bank (New York) — — — *$19 East St. Louis & Suburban, pfd — — — 72 common — — 36 East Side State Bank (Minneapolis) — — 130 East Side R. E. Tr. (Boston) — — $100 East Washington Savings Bank — — 15l^ 17 Eastern Light & Fuel *114 Eastern Pennsylvania Railroad $66l^ — Eastern Pennsylvania Railways, com — — 5 Eastern Power & Light, pfd *95 *95 Eastern Steel, 1st pfd „ __ *65 Eastern Trust & Banking (Bangor) — 325 Eastern Underwear Manufacturers *10 *10 Easthampton Gas tl50 Eastman Kodak, pfd __ — 123 124 common — __ 695 705 Easton Consolidated Electric ($25 paid) __ __ $20 $22 Edison Electric Hlum., Boston (Ist inst. pd.)_ __ 175 • (fully paid) — __ 275 281 Edison Elec. HI. of Brockton __ __ „ t202 Edwards Manufacturing (Maine) *65 Eighth Avenue Railroad __ — 300 Eighth National Bank (Philadelphia) *401 *401 Eisenstadt Manufacturing, com 127 Eisner-Mendelson Co., pfd __ __ '6 *7 Electric Boat Co., com __ __ __ *10i/. Electric Bond Deposit, pfd __ __ _. 8O14 Electric Bond & Share, pfd ._ __ 9914 101 Electric City Bank (Scranton) __ __ $74 $78 Electric Co. of America __ __ $1178 Electric Investment, com 50 ■ preferred __ _, 100 Elec. Lt. & Pow. Co. of Abington & Rockland __ __ „ tl95 Electric Storage Battery, com __ __ 51l^ 62 Electrical Development, pfd. *85 Electrical Security, pfd __ __ 82 Electrical Utility, com __ __ 34 38 preferred __ 80 82 Electro Lamp __ __ *85 Elgin National Watch __ __ 138 142 Elizabeth Gas Light __ __ 325 Elizabeth & Trenton Railway __ _> ♦71/2 — ♦Quotation nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1028 High Low Bid Asked El Paso (Colorado Springs) — — 5.70 5.94 El Paso Consolidated Mining GVa 6 El Paso Electric, com — — 114 preferred — — 95 97 El Paso Gold — — 5.90c 5.99c Elkton Consolidated — — 61c GlVsC Elraira & Williamsport Railroad, com *$5iy8 ~ preferred $70y2 __ Ely Consolidated (6th assessment paid) 16c 16c Ely Walker Dry Goods, com — — 84 85 1st preferred — — — 103 2d preferred — — — 81 Ely Witch Copper — — 5c 7c Emerson-Brantingham, com. 56% 56% - — preferred — — 93 97 Emerson Steam Pump *12 Empire & Bay State Telephone — — 60 72 Empire Cotton Oil, pfd — - — *96 Empire Dist. El., com — — 50 preferred — — 80 84 Empire Gas & Electric, com — — 60 ■ preferred — — 80 84 Empire Steel & Iron, com — — 10 13 • preferred . — — 43 45 Empire Title & Trust (Philadelphia) *$20y3 *$20y2 __ Empire Trust (New York) — — 300 England National Bank (Little Rock) __ — 120 Englewood State Bank (Chicago) __ __ 172 176 English Marconi — __ 17 22 Enoree Manufacturing (South Carolina), com. — — — 55 preferred — — — 100 Ensley Land -_ __ $105 $120 Enterprise Bank (Charleston) __ __ 125 130 Enterprise Manufacturing (Georgia) — __ 63 67 Equitable Guar. & Trust (Wilmington, Del.)_ __ __ 235 245 Equitable Ilium. Gas Lt. (Philadelphia), pfd._ __ __ 108 110 Equitable Real Estate, Ltd __ __ 138 Equitable Trust (New York) __ __ 495 505 Erie, com 27% 27 Ist preferred 43y2 43y3 2d preferred __ __ 35y2 35% Erie & Kalamazoo __ __ $100 $115 Erie & Pittsburg Ry. (gtd. Pa. R. R.) __ __ *$65 $70 Erie (Pennsylvania) Trust Co __ __ 160 Esmond Mills (Rhode Island), pfd »_ __ 100 103 Essex & Hudson Gas __ __ 132 136 Essex County National Bank (Newark) __ __ 150 155 Essex Street Trust (Boston) __ __ $90 $95 Euclid Oil __ __ __ 25c Eureka Pipe Line __ __ *355 *365 European & North American Railway __ __ __ *125 Everett Mills (Massachusetts) *150 Excelsior Trust & Savings Fund *$60 *$60 Exchange Bank (New Orleans) __ __ 145 Exchange Bank (Savannah) >_ __ 140 Exchange Banking & Trust (Charleston) __ __ 155 160 Exchange National Bank (Little Bank) __ __ 180 Exchange National Bank (Seattle) __ __ 160 175 Exchange State Bank (Kansas City, Kan.) ___ __ »_ 165 •Quotation nearest March 1, 1913. No quotation on that date. 1039 High Low Bid Aiked Exchange Trust (Boston) — — 150 Exchequer Mining (Nevada) — — Ic 2c Exeter Manufacturing, pfd — — — *47 common — — *22 Exposition Cotton Mills (Georgia) __ — — 150 Factors Insurance (Memphis) 96 100 Factory Building Trust (Boston) __ __ __ $92 Fairbanks (E. & T.) 268% __ Fairmont Creamery, pfd ^_ __ __ *99 Fairmount Park & Haddington $60^4 ~ Fairmount Park Trans $10 Fairmount Sav. Tr. (Philadelphia) *110 *110 Fairview Gold Boulder Mining (Nevada) 2c 4c Fairview Savings Bank (Detroit) — — 157 165 Fajardo Sugar — __ — *64 Fall River Electric Light 198 198 Fall River Gas Works — __ 300 310 Fall River (Massachusetts) National Bank— __ — 128 132 Fanny Rawlings (Colorado Springs) '. — — __ 4c Farmers & Mech. Nat'l Bank (Ft. Worth) __ __ — 228 Farmers & Mech. Nat'l Bank (Philadelphia) ♦140 '140 Farmers & Mech. Nat'l Bank (Fred'k) __ — $40 Farm. & Mech. Nat'l Bank (Washington)— __ __ 250 Farmers & Mech. Saving Bank (Davenport) — __ 250 260 Farmers & Merch. National Bank (Baltimore) — — $49 Farm. & Merch. Nat. Bank (Los Angeles)— — — 400 405 Farmers & Merch. Nat. Bank (Washington) „ — __ 250 Farmers & Merchants' Trust (St. Louis) — — 160 Farmers & Ship. Tob. W., com. „ — — 30 1st preferred — — — 100 2nd preferred — — — 80 Farmers Bank (Wilmington, Dela.) __ — $120 $135 Farmers Dep. Nat. Bk. (Pittsburgh) •$117 '$116 Farmers Loan & Trust Co. (New York) — — *$640 *$648 Farmers National Bank (Reading) — — $91 $95 Farmers National Bank (York) — — 175 180 Farmers Trust Co. (Minneapolis) — — 150 Farmers Trust (Lancaster) — — '260 *262 Farmington River Power — — $55 Farr Alpaca (Massachusetts) — — 350 355 Favary Tire — — — *15 Favorite (Colorado Springs) — — — .002c Fay & Egan, pfd. — — 75 100 Fayette Co. Gas — — ^108 '110 Fayette National Bank (Lexington) — __ — 250 Federal Light & Traction, com. — — 30 31 -preferred __ — 80 81 Federal Mining & Smelting, com. — — 12y2 16 ^preferred — — 36% 41 Federal National Bank (Pittsburgh) *$178 *$178 Federal National Bank (Washington) >_ __ 137 139 Federal Sign System, pfd — „ $85 Federal Signal (Troy), pfd. — — — '25 common — — *8 *14 Federal St. & Pleasant Vy. Pass. Ry -. — $181/3 $20 Federal Sugar Refining, com „ — *48 *51 ^preferred — ~ '88 ♦92 Federal Trust (Boston) ~ — 138 140 'Quotation nearest March 1, 1913. No quotation on that date. 1030 High Low Bid Asked Federal Trust (Newark) __ __ 235 Federal Trust (Philadelphia) •125 •125 Federal Utilities, com. __ __ 40 preferred __ 70 77 Federator Mining & Milling . __ — *36 Fidelity Bank (New York) __ — 165 175 Fidelity & Col. Tr. (Louisville) — __ 267 268 Fidelity & Deposit (Maryland) __ __ $1751/2 $1751/2 Fidelity Dep. & Dis. Bk. (Scranton) __ __ $160 $170 Fidelity National Bank (Seattle) — — 150 175 Fidelity-Phenix Insurance (New York) __ __ 310 320 Fidelity Title & Trust (Pittsburgh) __ „ __ *140 Fidelity Trust (Baltimore) „ __ 250 260 Fidelity Trust (Buffalo) __ __ 250 300 Fidelity Trust (Hartford) _.. __ __ 200 Fidelity Trust (Indianapolis) __ __ 110 Fidelity Trust (Kansas City, Mo.) __ __ 300 >_ Fidelity Trust (Newark) __ — __ 775 Fidelity Trust (New York) __ __ 218 Fidelity Trust (Philadelphia) *1176 '1176 Fidelity Trust (Portland, Me.) __ __ 215 220 Fidelity Trust (Rochester) __ __ 250 300 Fidelity Trust (Tacoma) ^ __ __ __ 200 Fifth National Bank (New York) „ __ 300 325 Fifth-Third National Bank (Cincinnati) __ __ 200 205 Fifty Assoc. (Boston) __ __ $4000 Fifth Avenue Bank (New York) __ __ *4,500 Finance Co. (Philadelphia), 1st pfd. *119 *119 2nd preferred *108 *108 Finance & Guaranty Co., pfd. — __ •lOO Findley (Colorado Springs) 4%c 5c Fire Association (Philadelphia) $350 Firemans Fund (San Francisco) __ 240 246 Firemen's Insurance (Newark) __ $245 Firemen's Insurance (Washington) __ __ $19 $22 Firestone Tire & Rubber, com. 295l^ preferred __ 105l^ __ First Bridgeport National Bank — __ 230 First Mortgage Guarantee (New York) __ __ 125 130 First Mtge. Guar. & Tr. (Philadelphia) *98 *98 First National Bank (Albany) __ __ 160 170 First National Bank (Altoona) __ __ 330 350 First National Bank (Baltimore) __ __ 144 146 First National Bank (Bangor) 152 First National Bank (Beaumont) __ __ 300 First National Bank (Birmingham) __ __ 260 270 First National Bank (Boston) __ __ 475 480 First National Bank (Brooklyn) __ __ 280 300 First National Bank (Burlington) __ __ __ 150 First National Bank (Camden) *170 *170 First National Bank (Charleston) __ __ 350 375 First National Bank (Charlotte) __ __ 185 First National Bank (Chicago) __ __ 444 446 First National Bank (Cincinnati) __ __ 208 210 First National Bank (Cleveland) 221l^ __ First National Bank (Covington) __ __ 160 165 First State Bank (Dallas) __ __ 130 131 First National Bank (Davenport) __ __ 300 325 First National Bank (Detroit) __ __ 198 201 *QuotatIoQ nearest March 1, 1913. No quotation on that date. 1031 High Low Bid Asked First National Bank (Duluth) __ __ 450 First National Bank (Erie) __ __ 210 First National Bank (Fall River) __ __ 200 First National Bank (Ft. Worth) __ _. __ 200 First National Bank (GaWestonj __ __ 130 140 First National Bank (Guthrie) __ __ 145 First National Bank (Harrisburg) __ __ 575 600 First National Bank (Hartford) __ __ 174 First National Bank (Hoboken) __ __ 95 100 First National Bank (Houston) 175 First National Bank (Jersey City) __ __ 330 340 First National Bank (Kansas City, Mo.) * __ __ 625 First National Bank (Lancaster) 235 240 First National Bank (Lexington) __ __ 150 155 First National Bank (Los Angeles) 725 First National Bank (Louisville) __ __ 185 First National Bank of McAlester 160 First National Bank (Memphis) __ __ 2721/2 275 First National Bank (Milwaukee) __ __ 205 First National Bank (Minneapolis) __ __ 305 320 First National Bank (Morristown) 274 First National Bank (Muskegon) 165 First National Bank (New Bedford) __ __ 143 145 First National Bank (New Haven) 183 First National Bank (New York) __ __ *990 1005 First National Bank (Norwich) 85 First National Bank (Omaha) __ __ 275 300 • First National Bank (Paterson) __ __ 275 295 First National Bank (Philadelphia) *230 *230 First National Bank of Pittsburgh __ __ 160 First National Bank (Portland, Me.) __ __ 120 122 First National Bank (Reading) __ __ 150 155 First National Bank (Richmond) __ __ 277 283 First National Bank (San Francisco) __ __ 227y^ — First National Bank (Scranton) __ __ 347V2 355 First National Bank (Seattle) __ __ 225 ~ 240 First National Bank (Shreveport) __ __ 190 200 First National Bank (Terre Haute) __ __ 275 300 First National Bank (Toledo) __ __ 285 First National Bank (Trenton) 222 222 First National Bank (Utica) __ __ $88.80 First National Bank (Waco) __ __ 190 215 First National Bank (Wilkesbarre) __ __ 260 270 First National Bank (York) __ __ 104 105 First National Copper __ 2ys 2^ First National Englewood Bank (Chicago)— __ __ 315 First Savings and Bank (Dayton) 150 First Savings Bank & Trust (Nashville) __ __ 125 130 First Ward National Bank (Boston) 180 180 Fisk Rubber, Ist pfd. __ __ __ *102ya Fitchburg Gas & Electric Light "125 *125 Fitchburg (Massachusetts) National Bank 170 175 Fitchburg Railroad, pfd. __ __ __ 120 Fitchburg (Mass.) Safe Deposit & Trust __ — 145 150 Flannery Bolt — __ *280 Fleischmann, pfd. __ __ 120% — Fletcher American Nat'l Bank (Indianapolis) __ __ 242 Fletcher Savings & Trust (Chicago) — __ 200 Flexible Steel Bolting __ __ — 'SO *Quotation nearest March 1, 1913. No quotation on that date. 1032 High Low Bid Asked Flint Mills (Fall River) __ __ __ 97 Florence Gold Fid. Mining (Nevada) 65e 48c Florida National Bank (Jackson) __ 200 Flower of West (Colorado Springs) __ __ 003c Ic Foard (Jos. R.) Co. *100 *100 Fore River Shipbuilding, pfd. __ __ __ *23 common *3 Ft. Dearborn National Bank (Chicago) __ __ 254 262 Ft. Smith Light & Traction, pfd. __ __ 90 921/3 Ft. Wayne & Jackson Railroad, pfd. __ __ 122 130 Ft. Wayne & No. Ind. Trac, com __ __ 15 18 preferred 60 70 Ft. Wayne, Van Wert & Lima Trac, pfd. __ __ *62 *65 Ft. Worth National Bank __ __ 325 450 Ft. Worth (Texas) Power & Light, pfd __ __ __ *104 Ft. Worth State Bank __ __ __ 125 42nd St. & Grand St. Ferry R. R __ __ 260 285 Foss (H. D.) & Co., pfd. _» __ *6.51% basis Foster Cobalt Mining __ __ 7c rac Fourth & First National Bank (Washington) >_ __ 245 250 Fourth Atlantic National Bank (Boston) __ __ 192 195 Fourth National Bank (Atlanta) __ __ 268 275 Fourth National Bank (Cincinnati) 270 Fourth National Bank (Dayton) _« »» 160 164 Fourth National Bank (Grand Rapids) __ ._ 210 Fourth National Bank (Jackson) __ __ 135 Fourth National Bank (Macon) __ __ 165 167 Fourth National Bank (New York) _« __ __ 195 Fourth St. National Bank (Philadelphia) *315 *315 Frances -Mohawk Mining (Nevada) 2c Frankford & Southwark Pass. __ __ $3671/2 -u- Frankford Trust (Philadelphia) *$161 *$161 Franklin Bank (St. Louis) __ __ __ 305 Franklin Co. (Maine) *205 Franklin Fire Insurance (Philadelphia) *$46 Franklin Insurance (Washington) — $30 Franklin Mining __ __ ey^ 6^^ Franklin National Bank (Philadelphia) *500i4 *500iA __ Franklin Savings Bank (Fredericksburg) __ __ 110 Franklin Teleg. __ __ 40 50 Franklin Trust (Brooklyn) __ __ __ 250 Franklin Trust (Philadelphia) *$55 *$55 Franklin Trust & Savings Bank (Chicago) __ __ __ 160 165 Frederick Co. Nat'l Bank (Fredericksburg)— __ __ $211/2 __ Frederick Town Savings Institution (Fred'k) >_ __ 170 Freeman Daughaday Co., pfd. *6l^% basis Freemans, Limited — — — *112l^ Freihofer Baking, pfd. __ __ — *100 French Opera Assoc, Ltd. __ __ 52% 95 Fries Manufacturing & Power __ — *25 Frisbie & Stansfield Knitting, pfd. __ -_ 99 101 Friscoville Realty *130 Frost-Johnson Lumber __ — *75 Fullerton Oil — __ 2 31/3 Fulton National Bank (Atlanta) . __ — 128 132 Fulton National Bank (Lancaster) __ — 235 240 Fulton Trust (New York) __ — 295 315 *Quotatlon nearest March I, 1913. No quotation on that date. 1033 High Low Bid Asked Gaffney Manufacturing (South Carolina) __ __ 55 65 Gair (Robert) Co., pfd. •100 •100 Galena-Signal Oil, pfd. — — 135 139 . common — — 293 297 Galveston-Houston Electric, com. — __ 98 preferred — — 94 Gardner Electric Light, pfd. — .. __ •1071/3 common — — — — ^157 Gardner Gas, Fuel & Light — — — flSO Garfield National Bank (New York) -_ __ 265 275 Garfield Savings Bank (Cleveland) __ 195 Garford Co., pfd. '100 Gary & Interurban __ — ♦$14 •$171/3 Gas & Electric of Bergen Co. — — 88 90 Gas & Electric Securities, com. — __ ^140 "150 preferred — — — *94i/4 Gate City National Bank (Kansas City, Mo.) „ — 120 123 Gauley Land Coal, pfd. _- _> __ •SO General Acoustic Co. — — — ^45 General Asphalt, com. — __ 38% 3914 ■ preferred — — 73 74 General Baking, com. — — 19 22 preferred - — — 69 72 General Chemical, com. — >_ 175 200 preferred — — 105 110 General Cigar — See United Cigar Mfrs. General Development — — 90 110 General Electric I3914 139 General Film, pfd. __ — — ^95 General Fire Extinguishing Co. __ __ __ ^166 General Founders Co. — — — *12 General Gas & Electric, pfd. — — •84 •871/3 common — — •ISi/a ^25 General Manifold & Printing „ — •SVg __ General Motors, com. vtg. Tr. Ctfs. __ — SQi/o 34 preferred — — 75 79 General Petroleum — __ 27% 28I/3 General Railway Signal, com. __ 60 62 preferred — — 90 96 Genesee Valley Trust (Rochester) „ „ 190 200 Georgetown Gaa — — $85 $135 Georgia Light, Power & Railways, pfd. __ — — *96 common — — *35 ^39 Georgia Railroad & Banking Co. — „ 256 260 Georgia Railway & Electric, 8% gtd. stk __ __ •llS ^121 preferred __ — 831/3 841/3 Georgia Railway & Power, com. __ __ 23 241/3 1st preferred — — 81 821/3 2nd preferred — — 39 41 Georgia Savings Bank & Trust (Atlanta) — __ 175 185 Georgia Southern & Florida, com. — — 30 36 1st preferred — — — 95 2nd preferred __ — SOi/, 81 German-Alliance Insurance (New York) — — 275 290 German -American Bank (Baltimore) __ — 108 112 German -American Bank (BuflFalo) — — 260 German-American Bank (Detroit) — — 180 German-American Bank (Kansas City, Mo.)__ — __ 600 German -American Bank (Milwaukee) — — 135 140 •Quotation nearest March 1, 1913. No quotation on that date. t"Value" as of March 1, 1913. 1034 High Low Bid Asked German-American Bank (Minneapolis) __ 200 German- American Bank (New York) *$105 German- American Bank (St. Louis) 197 German -American Bank (Seattle) 110 125 German -American Coffee *^V» German-American Fire Insurance 270 German- American Insurance (Baltimore) _« __ $40 $50 German -American Insurance (New York) — 540 650 German -American Nat'l Bank (New Orleans) 179 German- American Savings Bank (Burlington) __ __ __ 300 German -American Savings Bank (Cleveland) 125 German-American Sav. Bank (Los Angeles) 385 395 German-American Sav. Bk. & Tr. (New Orl'ns) *211 German- American State Bank (Saginaw) 140 145 German-American Sugar *10 German-American Title & Tr. (Philadelphia) *$95i4 *$95i4 German-American Trust (Paterson) 370 German-American Tr. & Sav. Bk. (Los Ang.) _«- __ 385 397^^ German Bank of Baltimore 110 115 German Bank (Louisville) __ 330 350 German Bank (Wheeling) __ _« 500 German Exchange Bank (New York) __ 400 German Insurance (Baltimore) $17y2 $19 German Insurance (Louisville) $50 German Insurance (Pittsburgh) __ $75 $85 German Insurance Bank (Louisville) $150 German National Bank (Cincinnati) 300 320 German National Bank (Little Rock) __ 120 German National Bank (Newport, Ky.) 175 German National Bank (Pittsburgh) *$200 *$200 German Savings Bank (Burlington) __ __ 405 410 German Savings Bank (Davenport) 285 300 German Savings Bank & Trust (Memphis)— __ __ 600 700 German Savings Institution (St. Louis) 470 480 German Sav. & Loan Soc. (San Francisco) $3160 German Securities Bank (Louisville) __ 1721/3 175 German Theatre Realty *^V4:% basis Germania Bank (New York) '475 *475 Germania Bank (Savannah) 179^/2 Germania Half-Dlr. Sav. Bk. (^Vheeling) __ __ 206 Germania Insurance (New York) __ $155 $162l^ Germania National Bank (Milwaukee) 145 Germania Savings Bank (Atlanta) 100 105 Germania Savings Bank (Charleston) __ 430 450 Germantown National Bank (Covington) 135 145 Germantown Passenger Railway __ __ *$105 *$113% Germantown Trust (Philadelphia) *27iy2 *27iy2 Germany Mining & Development 50c 75c Giant Consolidated Co. '. __ 119 126 Gillette Safety Razor, pfd. __ __ *102 Girard Avenue Title & Trust (Philadelphia) *$70 *$70 Girard Copper 99c $1 Girard Fire & Mar. Insurance (Philadelphia) *$275 Girard National Bank (Philad^phia) *415 *415 Girard Trust (Philadelphia) *$990 *$990 Giroux Copper Mining 3 2% Globe Oil __ __ ly^c sy^c Globe Savings Bank (Los Angeles) __ 150 ^Quotation nearest March 1, 1913. No quotation on that date. 1035 Bid Asked 120 __ 110 105 145 __ 118 120 •108 ♦110 5c .005c IVaC "10 10c II1/2C Va . Va, 115 8c 10c 2.00 8.00 3c 5c High Low Globe Soap, Ist pfd. 2nd preferred special preferred Globe-Wernicke, com. preferred Goff (D.) Sons, pfd. Gold Bar Min. of Goldfield (Nevada) Gold Bond (Colorado Springs) Gold Car Heating & Lighting Gold Dollar (Colorado Springs) Gold Hill Mining Gold & Stock Telegraph Co. Gold Wedge Mining (Nevada) Golden Boulder Mining (Nevada) 3c 3c Golden Cycle (Colorado Springs Goldfield Bulldog Mining (Nevada) Goldfield Consolidated Mines (Nevada) $2.85 $2.75 Goldfield Daisy *5ya *5y2 Goldfield Florence *48 *44 Goldfield Kewanas Mining (Nevada) 4c 5c Goldfield Merger Mines (Nevada) 26c 27c Goldfield Portland Mining (Nevada) Goldschmidt Detinning, pfd. Goodrich (B. F.), com. 41 41 preferred Goodwins, Limited, com. preferred Goodyear Tire & Rubber, com. *365 preferred Gorham Manufacturing, pfd. Gosnold Mills Co. (New Bedford), pfd. Gotham National Bank (New York) Gottlieb -Bauer- Straus Gould & Curry Mining (Nevada) 3c 3c Granby Consolidated Min., Smelt. & Pr Grand Avenue Bank (St. Louis) Grand Rapids & Indiana Grand Rapids National City Bank Grand Rapids Railway, pfd. Grand Rapids Savings Bank Grand River Valley Railroad Grandma Mining (Nevada) Granite-Bi -Metallic (St. Louis) Granite Mills (Fall River) Granite Savings Bank & Trust (Barre) Graniteville Manufacturing (South Carolina) Grasselli Chemical, pfd. *104 *104 • common Gray-Davis, pfd. ♦lOS *105 Gray & Dudley Great Bend Annex Mining (Nevada) Great Bend Extension Mining (Nevada) Great Bend Mining (Nevada) Great Falls Manufacturing (New Hampshire) ISSVa __ Great Lakes Dredge & Dk. Great Lakes Engineering Great Lakes Towing, com. preferred •92 Great Northern, pfd. 126% 1261/, 'Quotation nearest March 1, 1913. No quotation on that date. 1036 •88 *94 97 98y, 40 41 80 81 103 105 1181/2 89 91 170 3 4 60% 61 215 24 30 181 __ 811/4 216 115 125 Ic 2c 30c 35c 115 100 138 142 175 •178 105 107 Ic Ic 127 •130 127 •130 •81 __ 15 High Low Bid Asked Great Northern Iron Ore Prop. __ 35 SSy^ Great Northern Life Insur. (Wausau, Wis.)— __ __ — *165 Great Western Beet Sugar, pfd. __ _- __ *101 Great West. Perm. Loan __ — — ISOVi Great Western Sugar, com. _- — SQVg 601/3 preferred __ „ 991/2 IOO1/3 Greater Gold Belt (Colorado Springs) __ __ .0015e Ic Greater New York Development Co — — — *13 Greeley Square Hotel, pfd. — — — *90 Greeley Square Realty — — — *26 Green Bay & Western, com. — — *82 93 Green & Coates Streets Pass. JRy. „ __ *$115 Green Ridge Bank (Scranton) — „ *66 *70 Greene Cananea 8^^ 8 Greenfield Electric Light & Power __ __ __ tl55 Greenfield Tap & Doe, pfd. __ — *5.63% basis Greenpoint National Bank (Brooklyn) __ __ __ 160 Greenwich Bank & Trust (Jersey City) — __ 275 300 Greenwich Bank (New York) __ — *250 260 Greenwood Cotton Mills (South Carolina) — _- __ 50 60 Grendel Mills (South Carolina) — __ 95 105 Greylock Mills — — — *122i/a Griffin Wheel, pfd. 1021/3 IO21/3 Grinnell Manufacturing (New Bedford) — — I671/3 — Guanajuato Development — — *10 *12 Guanajuato Power & Electric, com. — — 25 30 preferred — — 68 73 Guantanamo Sugar — — — *35 Guar. State Bank & Trust (Dallas) __ __ 130 135 Guarantee Title & Trust (Cleveland) *89% — Guaranty Trust (New York) n __ — 582 585 Guar. Trust & Safe Deposit (Philadelphia) __*$156i/4 *$156iA — Guarantee Tr. & Sav. Bank (Chicago) 133 Guar. Trust & Savings Bank (Jacksonville )__ __ 136 Guarantee Tr. & Bk. (Atlanta) „ __ 48 55 Guardian Savings & Trust (Cleveland) *300 Guardian Trust (New York) __ — 80 Guardian Trust (New York) __ __ $33 $34 Guggenheim Exploration $45% $45% Gulf Lumber ._ ._ __ *128 Guthrie (Oklahoma) Savings Bank 120 Hackensack Water Co., com. __ __ *$29i/2 — ■ preferred — __ __ *$29i/a Hadley Falls National Bank (Holy oke) __ __ 140 150 Hale & Kilburn, com. __ „ 68 65 1st preferred — „ 971/3 99 2nd preferred — — 96 98 Hale & Norcross Mining __ _- 6c 8c Halifax Electric Tramway Co. __ »_ 159 Halifax Tonopah Mining (Nevada) __ __ $1.05 Hall Signal „ ._ 1/4 ^4. Halsted St. State Bank __ „ 134 138 Hamilton Bank (Canada) __ __ — 208 Hamilton Brown Shoe __ __ 187l^ — Hamilton Manufacturing (Massachusetts) *90 Hamilton Prov. & Loan *132 Hamilton Trust (Brooklyn) __ __ 270 285 Hamilton Trust (Paterson) — 400 *Quotation nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1037 High Low Bid Asked Hamilton Trust (Philadelphia) *$43 *$43 Hamilton Woolen (Massachusetts) *90 Hancock Consolidated Mining _. __ 18 ISVg Hanover Insurance (New York) __ __ $971/2 $1021/2 Hanover National Bank (New York) __ __ *700 *710 Harb.-Walker Ref., com. __ __ 47 50 preferred 1 __ __ 101 Hargadine, McK. Dry Goods, 1st pfd. __ __ __ 80 2nd preferred 40 common 10 Hargiaves Mills (Fall River) __ __ __ 65 Harmony Mills, pfd. *114y2 __ Harriman National Bank (New York) __ __ 290 Harris Brothers, pfd. *100 *100 Harrisburg (Pennsylvania) National Bank__ __ __ $58 $60 Harrisburg, Ports., Mt. Joy & Lancaster *$92V2 __ Harrisburg (Pennsylvania) Trust Co. __ __ 200 210 Harris Trust & Savings Bank (Chicago) __ __ 525 Hart (Colorado Springs) __ __ __ 2c Hart & Crouse, pfd. __ __ *6.90% basis Hart, SchafFner & Marx, pfd. __ __ 97 98 Hartford & Connecticut West. __ 43 Hartford Carpet, com. __ 122 125 preferred 118 121 Hartford City Gas Light, pfd. __ __ $50 $52 common $66 $70 Hartford Electric Light __ __ 262 264 Hartford Fire Insurance (Hartford) __ __ 760 767 Hartford Gas Securities, com. $68 $70 preferred __ __ $50 $52 Hartford Insurance __ __ 760 770 Hartford National Bank 185 190 Hartford Steam Boiler Insurance __ __ 300 Hartford Trust Co. __ __ 425 Hartley Silk (Pennsylvania) $102^/2 $1021/2 Harwood Electric, pfd. *100 *100 common *39 *42 Havana Electric liight & Power, com. 84% Havana Electric Ry., Lt. & Pow., pfd __ __ *94 *99 Havana Tobacco, com. 4 6 preferred __ __ 8 15 Haverhill Electric __ __ __ t235 Hawaiian Commercial & Sugar __ __ $341/2 $3514 Hawaiian Sugar Co. , __ __ 34% __ Hayden (Colorado Springs) .002c Hayden- Clin ton Nat'l Bank (Columbus, Ohio) __ __ 225 250 Haymarket Trust (Boston) __ __ $70 $80 Hazark Manufacturing *45 '48 Hazel Pure Food Co., pfd __ __ ._ *3i/2 Heard National Bank (Jacksonville) 127 Hedley Gold Min __ _> 301/2 „ Heine Safety Boiler __ *70 Ilelme Co. (G. W.), com 175 188 preferred __ __ 100 106i/s Helvetia Copper 50c 75c Hendee Manufacturing, pfd __ __ *150 *160 Hennepin Co. Savings Bank (Minneapolis) __ __ 265 Henrietta Mills (North Carolina) __ _- 160 175 Hercules Powder __ __ •91 *92Va *Quotatlon nearest March 1, 1913. No quotation on that date. t"\'alue" as of March 1, 1913. 1038 High Low Bid Asked Hermitage National Bank (Nashville) 148 153 Hernando Insurance (Memphis) — — 97 100 Herr.-Hall-Marv. 10 20 Hestonville, M. & F., com — _- — $40 preferred : — — — $60 Hewson Pure Wool Tex., pfd. *7% basis Heywood Bros. & Wakefield, com — — 120 Hibernia Bank & Trust (New Orleans) — — 360 363 Hibernia Insurance (New Orleans) — — 170 210 Hibernian Bank of Savings — — 172^^ — Hibernian Savings Bank, Los Angeles — — 117 High Grade Oil, pfd *$104 "$104 High Street Bank (Providence) — — $94 Hill Manufacturing (Maine) *115 Hilliard Hotel Co., pfd '100 Hillside Bank (Brooklyn) __ — .,- 125 Hobart Trust (Passaic) — — 255 Hoboken (New Jersey) Trust — — 235 Hochelaga Bank (Canada) — — 150 155 Hocking Valley Products 4 5 Hocking Valley Railway — — — *150 Holland-St. Louis Sugar, pfd *10 common — 4^ 5l^ Hollenbeck Press, pfd __ — __ *100 Hollinger Gold Mines — _- 16 17 Holmes (D. H.) Co., Ltd __ — 152ya 160 Holmesburg Trust (Philadelphia) *$55 *$55 Holyoke National Bank — __ 195 205 Holyoke Street Railway — __ 180 185 Holyoke Water Power __ -_ 400 Home (Colorado Springs) 2c Home Bank of Canada _ . *115 Home Bank & Trust (Chicago) __ «_ 150 154 Home Insurance (New York) 740 755 Home Life Insurance of America *30 Home National Bank (Hoh^oke) 145 150 Home Saving Bank (Cincinnati) __ 100 110 Home Saving Bank (Detroit) 350 Home Savings Bank of Los Angeles 140 Home Saving Bank (Toledo) _. -_ 215 217^4 Home Savings Bank, Washington __ 325 Home Telephone, com __ ._ 10*4 10l^ preferred — — 27% 28% Home Trust (Brooklyn) __ __ 118 Homes Manufacturing (New Bedford), com.__ >_ — 100 preferred — — 107 108 Homestake Mining _- -_ 116 120 Homestead Bank (Brooklyn) __ — 85 100 Honokaa Sugar Co — 7% Honolulu Oil Cons __ — 1.07ya — Hood Rubber, pfd "116 Hooven Owens & Rent., pfd __ >_ -_ 100 Horner (R. J.) & Co., 1st pfd ^98 '98 Hoster Columbus Brewing, com 2 preferred 14% Hotel Bellev. Tr. (Boston) _. __ $50 Hotel Somerset Tr. (Boston) __ __ __ $85 Hotel Tr., T'raine (Boston) __ __ $110 $118 •Quotation nearest March 1, 1913. No quotation on that date. 1039 Bid Asked ^Vz 4% $18 $19 $23 __ 70 92 __ •105 99 101 285 325 — 19V2 80% 81 •50 •100 16 19 129 133 380 400 2% 3M, 7 10 *10 ^_ 600 135 145 4 7 14 $105 High Low Houghton Copper Houghton Co. Elec, com ■ preferred Houghton County Tr., com preferred Houghton & Button Building, pfd Houston G. & F., pfd Houston National Exchange Bank Houston Oil, com preferred 62% 62% dividend obligation Howard Investment, pfd common Hudson Companies, preferred Hudson Co. Gas Hudson Co. National Bank (Jersey City) Hudson & Manhattan, com ' preferred Hudson Motor Car Hudson Trust (Hoboken) Hudson Trust (New York) Huebner-Toledo Brewing, com preferred . Humboldt Insurance (Pittsburgh) Humboldt Savings Bank (San Francisco) — — — 129 Huntingdon & Broad Top, com $11 ^preferred $301/2 $30 Huron & Erie *218y2 — Hutchinson Sugar Plantation Hyde Park State Bank (Chicago) Hydraulic Pr. Br., com • preferred Hygienic Food Idaho Light & Power, pfd ■ common Idaho Railway, Light & Power Illinois Brick 70l^ 70*4 Illinois Central, com 123 123 4% stk. tr. ctfs. Ser. A Illinois Central leased line 4% stock Illinois Crude Oil 111. & Miss. Telegraph Illinois Traction, com preferred Illinois Trust & Savings Bank (Chicago) Imperial Bank (Canada) Imperial Life Assurance *50 Importers & Traders Nat. Bank (New York) Independence Trust (Philadelphia) ^$92 *$92 Independent Brewing, com ■ preferred Independent Harvester Indian Head Mills •25% ^25% Indian Refining, pfd ■ common ^_ Indiana Col. & Eastern Trac, pfd Indiana Lighting Indiana Mining 'Quotation nearest March 1, 1913. No quotation on that date. 1040 $16% 142 145 3 aVs 47% — •3% •29 ♦4 — •45 79 84 •90 •94 5c $32% $37 65 94 490 500 218 220 ^547 555 i48/» $4% $303/^ — •60 •25 •35 •5 •11 •50 40 43% 12% 13 High Low Bid Asked Indiana National Bank (Indianapolis) __ __ 30914 __ Indiana Pipe Line __ __ $133 $136 Indiana Trust (Chicago) 202 Indiana Union Tr 6% Indianapolis Abattoir, pfd. ■ : __ __ __ *100 Indianapolis Gas __ $40 $48 Indianapolis & Southeast. Tr., pfd. __ __ 821/3 90 Indianapolis Street Ry. __ __ 99l^ 991/3 Industrial Building *85 Industrial Trust (Providence) __ __ 246 251 Industrial Tr., Title & Savings (Philadelphia) *$175 *$175 Ingersoll-Rand, com. 105 preferred 92 Inland Steel __ __ 223 225 Inspiration Consolidated Copper $161/3 $161/3 Insur. Co. of North America (Philadelphia)— $22 $21% Insurance Co. State of Pennsylvania *$250 Integrity Title, Ins., Tr. & Safe Dep. (Phila.) *$154 *$154 Interborough Metropolitan, com. 17 preferred 58l^ Intercolonial Coal/ com. *85 preferred *64 Intercontinental Rubber 8 9 Interior Mining *5c *5c International Ag. Corp., com. 40 preferred ^_ 79 86 International Bank of St. Louis '_ 375 International Banking 100 115 International Belanger Ring __ 50c 75c International Button-Hole Sewing Machine $51/3 $6 International Coal & Coke *40 International Construction 10 20 International Educational Pub., com. $19% $20% ■ preferred ! $38 $40 International Elevating __ *50i/3 __ International Harvester, com. (old) 107 108% preferred (old) __ __ II01/3 113 International Harvester of New Jersey IO61/3 111 International Harvester Corp. 107 111 International Lead *90 International Lumber & Development __ __ *lli/3 *13i/3 International Mercantile Mar., com. stk. ctfs. 4 4% preferred : 17 18 International Motor Co., pfd. *19 common .._ *5 *8 International Nickel, com. 145 147 ^preferred IO51/3 107 International Ocean Tel. __ __ 90 105 International Paper, com. 12 12 preferred 45 47 International P-A-Y-E Tramcar, Limited "S^. International Postal Supply __ __ *31 International Rubber, com. 8 10 preferred 90 100 International Salt 2 4 International Shoe, pfd. __ __ IO41/3 105 common __ 981/3 99 International Silver, pfd. __ 131 135 common __ 115 120 *Quotation nearest March 1, 1913. No quotation on that date. 1041 High Low International Smelting & Refining International Smokeless Pow. & Chem., com. preferred *$50 International Steam Pump, com preferred International Telegraph of Maine International Text Book International Traction (Buffalo), com. preferred International Trust (Boston) Inter-State Ind. Telep. Inter-State Nat'l Bank (Kansas City, Mo.) Inter-State Railways, pfd. Inter-State Tr. & Bkg. (New Orleans) lola Portland Cement, com. preferred Iowa Central, com. preferred Iowa National Bank (Davenport) Iowa State Savings Bank (Burlington) Iron Cap Copper, pfd. Iron Silver Mining Co. Iron Steamboat Co. (New Jersey) Ironbound Trust (Newark) Irving National Bank (New York) Isabella my^ •131/2 Island Creek Coal, com. 1 preferred Island Copper Co. Isle Royale Copper Jack Pot (Colorado Springs) Jackson, Lansing & Saginaw Jacksonville Traction, com. ^preferred Jade Oil Jefferson Bank (St. Louis) Jefferson Co. Savings Bank (Birmingham) Jefferson -Gravois Trust .(St. Louis) Jefferson Realty Corporation, com. 1st preferred 2nd preferred Jefferson Trust (Hoboken) 140 140 Jennie Sample (Colorado Springs) Jerry Johnson (Colorado Springs) Jersey Central Traction, com. Jersey City Trust (Jersey City) Jim Butler Ton. Mining (Nevada) Johns (H. W.) -Mansville Johns-Pratt Johnson Tin Foil & Metal Johnson Service Co. ; Joliet & Chicago (gtd. C. & A.) Journal Big. Tr. (Boston) Julia Consolidated Mining Jumbo Extension Mining (Nevada) 32c 32c Justice Gold Mining (Nevada) 1« Kal., Alegan & Gr. Rapids . Kaministiquia Power 'Quotation nearest March 1, 1913. No quotation on that dat«. 1043 Bid Asked 120 124 $20 $23 13 14 53 57 •331/2 _« 130 133 35 40 ♦82 •90 425 450 *5V2 500 525 $71/4 197 201 $9 $14 8 12 19 25 285 300 250 3% ^V2 190 __ *$1 215 197 201 52 63 861/2 •6I/2 24% 25 51/4C 6c 80 85 115 116 6c 8c 100 165 175 140 150 25 991/2 95 — 51/4C '. 6c 5c 5%c ♦70 250 73c 75c •95 •110 290 __ 180 190 •93 155 165 $50 ~ 2c ic __ 125 138_. 124 134 High Low Bid Asked Kansas City Brew., com. *7l^ preferred *39 Kansas City Casualty __ __ $12 $13 Kansas City, Ft. Scott & M., pfd. cert. __ 73 'ti Kansas City Home Telephone __ __ __ 116 Kansas City Life Insurance 300 Kansas City, Mex. & Orient, com. __ 13 preferred __ __ 2 5 Kansas City Outer Belt & El. Ry., com. __ __ *1 *2 preferred *2 *5 Kansas City Ry. & Light, com. _^ __ 16 18 preferred __ __ 30 37 Kansas City, St. Louis & Chicago, pfd. __ __ 100 125 Kansas City Southern, pfd.. 6O14 601/3 common __ __ 241/3 25 K. C. Stock Yards of Maine, com. __ __ 791/3 8OI/3 preferred 7914 Kansas City Stock Yards of Missouri __ __ *81 Kansas Gas & Electric, pfd. __ __ 971/3 100 Kansas Natural Gas 10 13 Kansas Trust (Kansas City, Kan.) _« __ 155 170 Kaspar State Bank (Chicago) : __ __ 234 238 Kayser & Co. (Julius), com. 85 95. 1st preferred __ __ IO21/3 110 Kee Lox Manufacturing 204 206 Kelley Island Lime & Traction *140 Kellogg Toasted Corn Flakes, com __ __ *1234 *13i/2 Kenduskeag Trust (Bangor) __ __ 175 Kennard Carpet, com. __ __ __ 125 preferred __ __ 112 Kensico Cemetery Association __ __ __ *65 Kensington National Bank (Philadelphia)— *$110 *$110 Kensington Trust (Philadelphia) *$60 *$60 Kent State Bank (Grand Rapids) 266 Kentucky Consolidated Mining (Nevada) __ . Ic 2c Kentucky Securities, pfd. 71 73 common 27 30 Kent Title Savings Bank & Tr. (Louisville) __ __ 110 Kentucky Wagon 52 65 Kenwood Trust & Savings Banks (Chicago) __ __ 170 Keokuk & Des Moines, com. __ __ 6 8 preferred 45 Kerr Lake Mining 3^ 3i/s Keweenaw Copper 2l^ 2% Keystone Bank (Scranton) __ __ $100 $105 Keystone Con. Min. & Mlg. Co. (Col. Springs) __' __ __ Ic Keystone National Bank (Reading) __ __ 287 300 Keystone Telephone, com. __ __ $12 $121/3 preferred __ __ $421^ $43 Keystone Watch Case *95l^ Eilauea Sugar Plan. __ __ 12 Kilburn Mill (New Bedford) __ __ __ 125 Killington National Bank (Rutland) __ __ 125 Kimball Big. Tr. (Boston) __ __ __ $75 Kimberly Consolidated Mines *17c "170 Kinemacolor Co. of America *10 *20 King (J. P.) Manufacturing, com. __ __ 80 85 King (John P.) Manufacturing, pfd. __ __ __ *106 King Crowther Corp. __ __ __ 'lO •Quotation nearest March 1, 1913. No quotation on that date. 1043 High Low Bid Asked King Paper Co. __ __ __ *13V3 King Philip Mills (Fall River) __ __ __ 135 Kings County Electric Light & Power __ __ 121 123 Kings County Mortgage Co. *90 Kings County Trust (Brooklyn) __ __ 520 Kingston & Pembroke Ry. *li4 Kinloch Long Distance Tel. __ __ llSi/g 119 Kittie Lane (Colorado Springs) ll^c 2c Klots Throwing Co., pfd. *102y2 *102y2 __ I^app Co., pfd. __ __ *105 Knickerbocker Ice, pfd. *75 *80 Knoxville Gas, pfd. __ __ 100 Kokomo, Marion & West. Tr. __ __ 90 Kolb Bakery, pfd. >_ __ __ 98y8 Kresge Co. (S. S.), com. __ __ 71 76 preferred __ __ 100 101 Kroger Grocery & Baking, com. 205 1st preferred __ __ __ 123 2nd preferred 125 Kruger Copper & Silver __ 10c 14c Kuskulana Copper — — 5l^ 5% La Belle Iron Works, com. 48 50 preferred __ __ 124 126 La Rose Consolidated Mines 2% 3 La Salle Copper __ __ 3y8 4 La Salle Extension University — — — *10y2 La Salle St. Trust & Sav. Bank (Chicago) __ __ __ 100 102 Lackawanna Coal & Lumber __ __ — *2% Lackawanna Railroad of New Jersey — — 93 96 Lackawanna Steamship *95 Lackawanna Steel 44 44 Lackawanna Trust & Safe Dep. (Scranton) __ __ $320 $325 Laclede Gas Light, com, 98 lOO^^ preferred — __ 98 100 Laconia Car, pfd. __ __ *105 *115 common __ — *50 *60 Lafayette Bank (St. Louis) — — 1100 Lafayette Insurance (New Orleans) __ __ $215 $250 Lake Copper __ __ 16% 17 Lake Erie & Western, com. __ __ 9 11 ^preferred __ __ 23 30 Lake of Woods Milling, com. __ __ 133 139 preferred — — — 119% Lake Shore Bank & Trust (Cleveland) *300 Lake Shore Electric Ry., com. *7 1st preferred *90 2nd preferred __ __ __ 25% Lake Shore & Michigan Southern — — 460 525 Lake Superior Corporation __ __ 26y2 27 Lakeview Land Co. *100 Lake View State Bank (Chicago) __ — 104 106 Lakeview Trust & Savings Bank (Chicago)— __ — 190 200 Lakewood Co. of Maine — — *94 Lancaster Cotton Mills (So. Carolina), com. — — 125 130 preferred __ — 95 100 Lancaster Co. National Bank __ __ $131 $132 Lancaster Mills (Boston and Clint., Mass.) — — — — *85 Lancaster (Pennsylvania) Trust Co. __ — 600 *Quotation nearest March 1, 1913. No quotation on that date. 1044 High Low Bid Asked Land Title Trust (Philadelphia) .— *500 *500 Landed Banking & Loan *140 Landers, Frary & Clark — __ $93 Langley Manufacturing (South Carolina) — __ __ __ 75 Lansing Fuel & Gas __ __ *53 Lanston Monotype 85% 86Va Laramie, Hahns Peak & Pac. — — 3c 4c Laurel Lake Mills (Fall River) „ __ _- 145 Laurens Cotton Mills (South Carolina) __ __ 127 130 Laurentian Granite Co., Limited *40 *40 Laurentide Co. __ __ 214 216 Laurentide Paper 212 215 Lawrence Gas Co — — 210 Lawrence Manufacturing (Mass.) 168 Lawrence (Massachusetts) Trust — 100 La\vyers' Mortgage __ __ 215 219 Lawyers' Title, Ins. & Tr. (New York) __ __ 203 210 Lehigh & New York, pfd. __ __ 9 12 Lehigh Coal & Navigation __ __ $881/2 $89 Lehigh Coal Sales __ __ 195 205 Lehigh Portland Cement *68 Lehigh Valley, com. $78% $78^4 preferred *$60 Lehigh Valley Coal Sales __ __ $©5 $105 Lehigh Valley Transit, com. __ __ $19 $191/8 preferred __ __ $34% $351/2 Lehigh Valley Trust (Allentown) __ __ $230 $2371/2 Lehigh & Wilkesbarre Coal __ __ $155 Lexington City (Kentucky) National Bank__ __ __ 195 200 Lexington Mining Ic Liberty Mills __ __ 50 60 Liberty National Bank (New York) __ __ 630 640 Liberty Trust (Boston) __ __ 165 Library Bureau, pfd. __ *95 *99 common *13 *20 Library Co. (Philadelphia) *17 Library Square Realty __ __ __ *1% Life Insurance Club of New York *8 Liggett & Myers Tob., com. __ __ 219 225 preferred __ __ 113 115 Lightning Creek Gold Drain __ __ 2% 2% Lincoln Gas 40 Lincoln Gas & Electric Light __ __ 29 33 Lincoln Manufacturing (Fall River) 98 Lincoln National Bank (New York) __ __ *360 Lincoln National Bank (Pittsburgh) __ __ 200 210 Lincoln National Bank (Rochester) 210 220 Lincoln National Bank (Washington) 152 Lincoln Safe Deposit (New York) __ __ __ *193 Lincoln Savings Bank (Louisville) 95 98 Lincoln Trust (Boston) 150 Lincoln Trust (Jersey City) __ __ 325 335 Lincoln Trust (New York) __ __ 125 135 Lindsay Light . __ __ 20 25 Lion Hill Consolidated Mines 78c 80c Lisk Manufacturing, pfd. __ __ *90 common *21 Lit Brothers __ __ $171/2 $181/3 Litchfield Manufacturing (Waterloo, Iowa.) *100 *100 •Quotation nearest March 1, 1913. No quotation on that date.. 1045 High Low Bid Asked Little Miami __ 104 Little Puck (Colorado Springs) __ ,003e .007e Little Rock Railway & Electric, com *120 ■ preferred •991/2 — Little Sch. Nav. R. R. & Coal $56 Live Stock Exchange Nat'l Bank (Chicago) __ __ __ 268 275 Live Stock National Bank (South America) 145 160 Lockhart Mills (South Carolina), com __ __ 55 65 preferred — 90 100 Lockwood Co. (Maine) •103% >_ Lockwood National Bank (San Antonio) 240 Locomotive Superheater Co __ _> *150 *300 Logan Co. Bank (Guthrie) __ __ 120 Logan Trust (Philadelphia) "135 •135 London & Canada Loan & Ag'y *122i4 __ London Electric ^29 London Street ^150 Lone Star Consolidated Mining (Nevada) Ic 2c Lone Star Life Insurance (Dallas) __ •llO Long Island R. R __ __ $201/2 $211/2 Loose-Wiles, com 34 34 1st preferred __ __ 101% __ 2nd preferred . 91 Lorain Street Savings Bank (Cleveland) $182 Lord & Taylor, com __ _> 60 90 1st preferred 81 91 Lorillard Co. (P.), com. __ __ 185 191 preferred __ 112 115 Los Angeles Athletic Club __ _> 8% __ Los Angeles Hibernian Savings Bank 117 Los Angeles Investment Co 4.05 Louisiana & Missouri River R. R., pfd ^140 Louisiana & Southern Indiana Traction ^250 Louisiana Sugar Exchange ^65 Louisiana & Missouri River, pfd — 130 145 Louisiana & Nashville ^ 133% 1331/8 Louisville Bridge Co __ __ 103 105 Louisville, Hend. & St. Louis, com 17 21 preferred 30 35 Louisville Home Telephone 100 103 Louisville National Banking Co 150 152 Louisville Public Warehouse 92% Louisville Title -_ »_ 125 130 Louisville Tobacco Warehouse, com __ __ 89 preferred __ 130 135 Louisville Trac, com 96V^ 97^4 preferred __ 109 110 Louisville Trust Co 171 172 Lovejoy's Wh. Tr. (Boston) __ __ $101 $107 Lowell & Andover __ 210 220 Lowell Bank (St. Louis) __ __ 120 125 Lowell Bleachery (Massachusetts) ^128 Lowell Electric Light _« 200 205 Lowell Gas __ ^300 Lowry National Bank (Atlanta) __ __ 248 252 Lozier Motor Co ^18 Lucky Tiger Comb. Gold Mining __ __ __ •$3.85 Ludlow Manufacturing Associates ^239 '239 Luhrig Coal Washing & Manufacturing "14 *Quotatlon nearest March 1, 1913. No quotation on that date. 1046 High Low Bid Asked Lumbermans National Bank, (Houston) — — 175 Lumbermen's Insurance (Philadelphia) *$97l^ Luzerne Co. National Bank (Wilkes-Barre)— __ — 130 133 Lykens Valley R. R. & Coal __ — $13 $17 Lyman Mills (Massachusetts) *117 Lynn Gas & Electric — __ — t470 MacAndrews & Forbes, pfd. *102yz *102ya __ common — __ 193 200 MacDonald (A.) Co., Ltd '95 *95 MacNamara Mining & Milling (Nevada) 21c 20c Machinists' National Bank (Taunton) — 150 Mackay Companies, com __ 81 85 —^—preferred 1- — 65 68 Macon (Georgia) National Bank 90 95 Macon (Georgia) Savings Bank — — 82 84 Mahoning Coal R. R., com _ __ _« ._ $462^/^ preferred — ~ $50 $54 Maine Central -_ — 105 107ya Maine & New Br. El., Pow., Ltd., 6% deb. stk ^104 Maison Blanche Co., com — — 87^^ preferred — — 105 Majestic Mines — — 46c 47c Maiden Electric — __ — t270 Maiden & Melrose Gas Light __ — — tl90 Mallory Steamship — — *21 Manayunk National Bank (Philadelphia) *263 *263 Manayunk Trust (Philadelphia) *$60y8*$60y8 Manchester Bank (St. Louis) — — 160 Manchester & Lawrence — 200 225 Manchester (Pennsylvania) Sav. Bk. & Tr.__ *$55 *$55 Manhattan Amal. Mining (Nevada) — — 3c Manhattan Beach Co *2 Manhattan Big Four Mining (Nevada) 92c 89c Manhattan Co. Bank (New York) — — $175 $180 Manhattan Cons. Mines Devel. Min. (Nev.) 6c 6c Manhattan Crescent Mining (Nevada) 6c 6c Manhattan Dexter Mining (Nevada) — — 4c 5c Manhattan Ry., com >_ __ 130ya 13iy3 Manhattan Savings Bank & Trust (Memphis) 630 560 Manhattan Shirt, com 50 60 preferred — >_ 100 102ya Manhattan Transit Uii ^iVs Manhattan White Caps Mining (Nevada) — — 7c 9c Manning, Maxwell & Moore, Inc — — *83 Manomet Mills — — *120 *125 Manufactured Rubber, com — — — $% preferred — — $4 $6 Mfrs. & Trdrs. Nat. Bk. (Buffalo) 400 Manufacturers Light & Heat, Pittsburgh — $51% $51% Manufacturers National Bank (Brooklyn) — __ $12iya$129 Manufacturers National Bank (Newark) — 270 Manufacturers National Bank (Philadelphia) •131l^*131l4 Manufacturers National Bank (Troy) _ — 450 Manufacturers National Bank (Waterbury) — 150 Manville Co., pfd — — 5y2% basis Maple Leaf Mill, com — — 60^ preferred — — 96y2 97 'Quotation nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1047 High Low Bid Asked Marconi Wireless Telegraph of America __ __ __ *5% Marconi Wireless Telegraph of Canada *4y2 Marconi Wireless Telegraph, Ltd., pfd. _« __ *17 'lOVa common __ __ *20y2 *22y3 Maricopa Northern __ eVgC 6%c Maricopa Queen 15c Maricopa 06 Oil __ __ 32c 48c Marine Bank (Norfolk) __ __ 270 290 Marine National Bank (Buffalo) __ 325 350 Marine National Bank (Milwaukee) 230 Maritime Tel. & Tel. Co., pfd *5.66% basis common *4%% basis Market Bank (Buffalo) __ __ 140 Market Exchange Bank (Columbus, 0.) __ __ 200 210 Market & Fulton National Bank (New York) __ __ 250 255 Market National Bank (Cincinnati) 240 275 Market Savings Bank (Toledo) __ __ __ 108 Market Street National Bank (Philadelphia) *181l^*181l^ Market Street Title & Trust (Philadelphia) *$33 *$33 Market Trust __ __ 130 140 Market Trust & Savings Bank (Chicago) __ __ 123 126 Marlboro Cotton Mills (South Carolina) __ __ 80 Marlborough Electric __ __ __ t230 : Vlarlborough Electric Securities t230 Marshall & Ilsley Bank (Milwaukee) __ __ 225 230 Mary McKinney (Colorado Springs) __ __ 64y2C 64730 Mary Nevin (Colorado Springs) __ __ __ Ic Maryland & Pennsylvania __ __ 31 36 Maryland Casualty $105 $105 Maryland Coal Co. of Maryland __ __ __ *9 Maryland Coal Co. of Virginia *10 Maryland Coal Co. of West Virginia *9l^ Maryland Motor Car Insurance __ __ __ *115 Maryland National Bank (Baltimore) __ __ $21 $23 Maryland Trust (Baltimore), pfd __ __ 119 common 117 119 Mascot Copper Co *2V4 Mascot Oil __ __ __ 65c Mason Valley Mines 7% 7% Massachusetts Bonding __ __ $145 $145 Massachusetts Breweries 45 50 Massachusetts Consolidated Mining 414 4% Massachusetts Cotton Mills 118 Massachusetts Electric Companies, com __ __ 16y2 — stpd. preferred __ __ __ jQi/^ Massachusetts Fire & Marine Insurance __ __ $175 $225 Massachusetts Gas Companies, com. __ __ 89% 90 preferred __ __ 92y2 94 Massachusetts Lighting Companies __ __ $118 $121 Massachusetta-Pocasset Nat'l Bank (Boston) __ __ 160 165 Massachusetts Title Insurance __ 50 Massawippi Valley Railroad __ __ 115 Massoletti Mines __ __ 2 2% Mathieson Alkali Works *40 Matoa (Colorado Springs) .005 Mattapan Deposit & Trust (Boston) __ __ 200 Maxwell Motor, 1st pfd __ __ __ *65 2d preferred __ __ __ ♦55 ♦Quotation nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1048 High Low Bid Asked May Department Stores, com — — 73 75 preferred — — 101 104 Mayflower Consolidated Mining (Nevada) — — Ic 2c Mayo Mills (North Carolina) — — 125 135 Mays Oil '- — — 18c 20c McCasky Register Co., pfd — — — ^lOO^j common — — — ^lOOi/g McCornick & Co. Bank (Salt Lake City) — — 350 355 McElwain (W. H.) 1st pfd — — 101 102 McKeen National Bank (Terre Haute) — — 175 180 McKinley-Darragh 2iW 2 Mechanics' American Nat'l Bank (St. Louis). — — 2771/2 280 Mechanics' Bank (Brooklyn) — — 108 115 Mechanics' Bank (New Hampshire) — — $90 Mechanics' & Farmers' Bank (Alabama) — — 345 355 Mechanics' Insurance (Philadelphia) *$50 Mechanics' & Metals Nat'l Bank (New York)- __ __ *250 255 Mechanics' Mills (Fall River) __ „ — 90 Mechanics' National Bank (Lowell) — — 153 Mechanics' National Bank (Providence) — — $60 Mechanics' National Bank (Trenton) __ — $150 Mechanics' National Bank (Worcester) — — 180 Mechanics' & Traders' Insur. (New Orleans) __ __ __ 160 Mechanics' & Traders' State Bank (Chicago). __ __ 132 138 Memphis Street Railway, com *64 preferred . __ 82 Mercantile Bank (Kansas City, Missouri) 125 127 Mercantile Bank (Memphis) __ >_ 225 230 Mercantile National Bank (Salem) 125 Mercantile National Bank (San Francisco) 220 Mercantile National Bank (Seattle) 105 125 Mercantile Trust (Jersey City) >_ 175 Mercantile Trust (Little Rock) __ __ $80 Mercantile Trust (Portland, Me.) __ __ 145 150 Mercantile Trust (St. Louis) __ __ 300 305 Mercantile Trust & Deposit (Baltimore) $158i4 $158l^ Mercantile Trust & Savings Bank (Chicago)— __ __ 123 126 Mercantile Trust (Trenton) __ __ 153 Merchants' Bank (Augusta) __ __ 225 235 Merchants' Bank (Canada) __ __ 187 190 Merchants' Bank (Rochester) __ __ 235 250 Merchants' Bank (Salt Lake City) __ __ 169 170 Merchants' Bank & Trust (Los Angeles) __ __ 150 Merchants' & Cl'k Savings Bank (Toledo) ___ __ __ 300 Merchants' Export National Bk. (New York). __ __ *$77 *$80 Merchants' & Farmers' Nat'l Bk. (Charlotte) __ __ 192 Merchants'-Laclede National Bank (St. Louis) __ 3031/2 __ Merchants' Loan & Trust (Chicago) __ __ 432 436 Merchants' & Manufacturers Bk. (Milwaukee) __ __ 113 115 Merchants' & Mechanics' Bank (Scranton)___ __ __ $1021/2 $1071/, Mcrchants'-Mechanics' Nat'l Bk. (Baltimore). $33% $33% Merchants' & Main Street Bank (Memphis). .. __ 123 130 Merch. & Mech. Tr. & Sav. Bk. (Birmingham) _. __ 134 140 Merchants' Mills (Fall River) __ __ 98 Merchants' & Miners Transportation _. ._ __ *67i/j Merchants' National Bank (Allentown) _. __ 240 260 Merchants' National Bank (Bangor) ._ __ __ 300 Merchants' National Bank (Boston) _. __ 300 305 Merchants' National Bank (Burlington) _. __ __ 225 ♦Quotation nearest March 1, 1913, No quoUtion on that date. 1049 High Low Bid Asked Merchants' National Bank (Chicago) __ __ 209 Merchants' National Bank (Dayton) — 148 Merchants' National Bank (Harrisburg) __ __ 275 280 Merchants' National Bank (Jersey City) __ __ 150 175 Merchants' National Bank (Los Angeles). __ __ 850 Merchants' National Bank (Lowell) __ 198 Merchants' National Bank (Newark) 260 Merchants' National Bank (New Hampshire)- $67 Merchants' National Bank (New York) __ __ *$98 *$100 Merchants' National Bank (Norwich) __ 110 Merch. National Bank (Omaha) __ 190 200 Merch. National Bank (Providence) __ $87 Merch. National Bank (Raleigh) 150 Merch. National Bank (Richmond) __ __ 1000 Merch. National Bank (St. Paul) __ ._ 255 275 Merch. National Bank (Salem) $85 $85. Merch. National Bank (Sav.) __ __ 115 Merch. National Bank (Topeka) _« 175 Merch. National Bank (Worcester) 190 Merch. Public Utilities, pfd __ __ __ *99 Merch. Real Estate Trust (Boston) __ __ __ $500 Merch. Savings & Trust (Pittsburgh) __ __ __ *$30 Merch. Trans. & Storage __ __ 105 120 Merch. Trust (Camden) __ __ 125 135 Merch. Trust (Lawrence) 155 Merch. Union Trust (Philadelphia) *110 *110 Merchants Warehouse Co *132 *132 Mergentlialer Linotype __ __ 217 218^4 Meriden Cutlery Co *21 Mermod, Jaccard & Co., pfd 90 Merrill Trust (Bangor) __ __ 175 Merrimac Chemical *$49ya*$49y2 Merrimack Manufacturing (Mass.), pfd *96 common 33*4 Metacomet National Bank (Fall River) __ __ 125 130 Metal Shingle & Siding Co., Ltd., pfd 'lOO '100 Metropolis, Bank of the (New York) __ __ *355 365 Metropolitan Bank (Canada) 200 Metropolitan Bank (Minneapolis) 135 Metropolitan Bank (New Orleans) 170 Metropolitan Bank (New York) >_ __ 190 197 Metropolitan Bank (Seattle) _« __ 250 300 Metropolitan Bank (Toronto) __ 200 Metropolitan Gas & Electric, pfd _« *91 Metropolitan National Bank (Washington)— 205 210 Met. State Bank (Detroit) __ .. 127 140 Metropolitan Trust (New York) _- __ 440 450 Mexican Crude Rubber Co ^ 14 Mexican Gold & Silver Min. (Nevada) 65c 64c Mexican Iron & Steel *8 Mexican Light & Power, com 74% 75Vi Mexican Metals __ 1% 1^^ Mexican Min 65 63 Mexican North. Pow 20 21 Mexican Petroleum, com 70*4 69% preferred ._ 93l^ 100 Mexican Plantation $165 $165 Mexican Telegraph ._ ._ "210 *230 *QuotatiOD nearest Marcb 1, 1913. No quotation on that date. 1050 High Low Bid Asked __ $31/2 $4 __ __ $61/4 __ *1 __ __ ♦70 108 110 $221/2 -$221/2 __ _„ 100 ^_ 142 146 __ __ _^ ♦95 ._- 190 __ __ •101/2 __ $93 98 100 __ __ UVz $2 210 99 1003/4 __ 45 93 600 __ __ ♦75 ♦81 — 42c 215 219 __ __ *30 ♦37 Mexican Telephone & Telegraph, com preferred Mexican Timberfields Co Mexican Trust Co. (Kansas City) Mexico Tramway Miami Copper Miami Pape*-, 1st pfd Michigan Avenue Trust (Chicago) Michigan Buggy, pfd Michigan Central Michigan Fence Co Michigan F. & M. Insurance Michigan Light, pfd Michigan Min Michigan Savings Bank (Detroit) Michigan State Telephone, pfd Michigan Sugar, com preferred Michigan Trust (Grand Rapids) Michigan United Ry Michigan-Utah Mining ;M^id-City Trust & Savings Bank (Chicago)—. Middlesex Banking Co Middlesex Co. (Massachusetts) 55 Midland Life Insurance Co — — ♦IS Midway Mining (Nevada) 54V2C 53c Midway Northern — 10c Milford-Uxbridge Co Miller (Daniel) Co Miller (Edward) Co. (Connecticut) Miller (Henry F.) & Sons Pianos, pfd Miller Rubber ^192 Miller Safety Device Corp Mills Manufacturing (South Carolina) Milwaukee & Chicago Brew Milwaukee Electric Ry. & Light, pfd Minehill & Schuylkill Haven $5714 $57l^ Mineral Hill Consolidated Mines (Nevada) Miners' & Merch. Bank (Charleston) Miners Bank of Wilkes-Barre Mines Co. of America Minneapolis Brew., com preferred Minneapolis & St. Louis, com I914 I914 preferred M. S. P. & S. S. M., com 136l^ I3614 preferred Leased Line Certificates Minneapolis Threshing Mach ^102 ^102 Minnesota Sugar, com preferred Miss. Central Miss. River Power, pfd common Mississippi Valley Bank & Trust (Memphis)- Mississippi Valley Trust (St. Louis) Missisquoi Marble Co ♦IS ♦IS Missouri & Kansas Telephone ^65 'Quotation nearest March 1, 1913. No quotation on that date. 1051 ♦77 ♦140 ♦60 ♦63 — ♦110 *1V2 95 100 $16 $20 ♦100 ♦102 ~" Ic 140 150 $205 $210 2% 2% — 180 100 — ♦43 — 143 150 82 83% 42 49 74 77 40 43 74 77 45 48 120 130 300 305 High Low Bid Asked Missouri, Kansas & Texas, com 25% 25% preferred — — 601/^ 60% Missouri Pacific 37% 37% Mizpah Extension Mining (Nevada) Mobile & Birmingham, pfd. (gtd.) Mobile & Ohio stock tr. ctfs Mobile Elec, pfd Modern Pen Co Mohawk Mining Mohawk Valley Co Moline Plow, pfd common Molsons Bank (Canada) Monadnock Mills (N. H.) Monarch Cotton Mills (South Carolina) Monarch Fence Co Monarch Knitting, com preferred Monarch Pitts. Ext. Mining (Nevada) 17c 16c Monaton Realty Investment Monongahela River Coal & Coke, pfd common Monongahela Valley Traction, pfd Montana Min *1.62y2*1.62i/2 Montana Power, com preferred Montauk Bank (Brooklyn) Montgomery (J. R.) Co Montgomery Ward, pfd Montpelier-Barre Light & Power, pfd Montreal, Bank of (Canada) Montreal Cottons, com preferred Montreal Light, Heat & Power Montreal Loan & Mortgage *190 Montreal Power Montreal Telegraph Montreal Tramways, com Montreal Tramway & Power Montreal Welland Land, Ltd., pfd *95 *95 Moon Anchor — — — Ic Moore (Benjamin) & Co *160 "leO Moore (L. E.) Stave Co., pfd — — — *110 Moore-Watson Co. (New York), pfd '100 *100 Morning Glory Min. (Nevada) Morris County (New Jersey) Traction Morris & Essex Extension R. R Morris & Essex R. R., gtd Morristown (New Jersev) Trust Co Morse Twist Drill & Machine Co. (N. Bedfd.) Mortgage Bond Mortgage Guarantee (St. Louis) Mortgage Trust (Philadelphia) *101iA *101i4 Motzorongo Plan Mount Morris Bank (New York) Mount Olivet Cemetery Mountain City Trust (Altoona) Mountain States Telephone & Telegraph Mulford (H. K.) Co •Quotation nearest March 1, 1913. No quotation on that date. 1053 51c 54c *65 75 771/a 92% 95 *10 $48 $49 *ioiy2^ •^108 1003/4 103 »140 201% 1000 105 115 *2% 86 — 93 "■ •50 *50 •75 novsj •20 ~ •85 451/2 46 99 101 150 90 1071/4. 107% *6% basis 242 59 6O1/4 1041/4 105 *224%^ »225 224% 225 $57% 170 45% 45% Ic 3c 3 4 •97% »$82% .*$86 400 300 __ 103 106 — 134 " •5 ^300 __ 90 100 $43 $45 104 105 __ •56 High Low Bid Asked Muncie, Hartford & Fort Wayne, pfd __ __ *60 Municipal Gas (Albany) ^ — — 265 280 Municipal Pub. Service, pfd *98 *98 Municipal E. E. Trust (Boston) — — $97 $103 Munsey Trust (Baltimore) ' — — 105 107 Murchison National Bk. (Wilmington, N. C.)- ~ — 160 161 Murray Co., com — — *150 *160 Muskogee Gas & Electric, pfd — — 95 971/2 Mustang Extension Mining (Nevada) — __ Ic 2c Mustang Manhattan Mining (Nevada) — — 3c Mutual Alliance Trust (New York) — __ 135 145 Mutual Bank (New York) — — 290 Mutual National Bank (Boston) — — 100 Mutual Savings Bank (San Francisco) __ __ — $80 Mutual Trust (Philadelphia) *$44 *$44 Mutual Trust (Port Chester) __ __ 140 150 Myles Salt Co., Ltd., com — — 125 preferred — — 125 Narragansett Electric Lighting __ __ $90 $92 Narragansett Machine, pfd __ — — *102l^ Narragansett Mills — — $115 Nashawena Mills (New Bedford) — — 70 75 Nashua & Lowell — — 243 Nashua Manufacturing (New Hampshire) *625i4 — Nashville, Chattanooga & St. Louis — — 150 170 Nashville & Decatur — — $46% $48 Nashville Gas __ — 100 105 Nashville Railway & Light, com 102^^ — preferred __ — 95% 96ya Nashville Title __ __ 95 102 Nashville Trust Co __ __ 150 160 Nashville Warehouse & Elevator __ __ 20 30 Nashville Woolen Mills __ __ 20 30 Nassau & Dutchess Insurance (New York) __ __ 130 140 Nassau National Bank (Brooklyn) 205 220 Nassau Trust (Brooklyn) __ __ 130 National Acme Manufacturing *110 National Bank of Baltimore 177 179 •National Bank of Barre 120 National Bank of California, Los Angeles _, __ 225 National Bank of Commerce (Baltimore) __ __ $311/3 $321/2 National Bank of Commerce (Boston) __ __ 235 230 National Bank of Commerce (Columbus, 0.)— __ __ 135 145 National Bank of Commerce (Dallas) __ __ 200 National Bank of Commerce, Detroit __ __ 211 218 National Bank of Commerce (Houston) __ __ $104 $106 National Bank of Commerce (Louisiana) __ __ 225 230 National Bank of Commerce (New York) __ __ 191 I931/3 National Bank of Commerce (Norfolk) __ __ 200 205 National Bank of Commerce (Providence) __ *67i/3 National Bank of Commerce (Rochester) __ __ 185 190 National Bank of Commerce (St. Louis) I491/2 I491/2 National Bank of Commerce (Seattle) __ __ 335 340 National Bank of Commerce (Tacoma) __ __ 350 National Bank of Commerce (Toledo) __ __ 140 144 National Bank of Cuba (Havana) __ __ 110 111 National Bank of Delaware (Wilmington) __ __ 215 225 National Bank of Germant'n (Philadelphia) _*$14 2 1/2 *$142i/3 •Quotation nearest March 1, 1913. No quotation on tliat date. 1053 High Low Bid Asked National Bank of Kentucky (Louisville) __ __ 200 2031/2 National Bank of New Jersey (New Bruns'k) — — 285 300 National Bank of No. Lib. (Philadelphia) •253 •252 National Bank of Petersburg (Virginia) __ __ __ 300 National Bank of Republic (Chicago) __ „ 230 234 National Bank of the Rep. (Kansas City, Mo.) — __ 160 175 National Bank of Republic (Salt Lake City). __ __ 195 200 National Bank of Savannah — — — 2321/3 National Bank of Washington, D. C __ — 244 256 National Bank of West Virginia (Wheeling) _ __ __ 158 160 National Ben. Franklin Insur. (Pittsburgh) __ $100 National Biscuit, com 115% 115% preferred — — 116 121 National Candy, com — — 914 10 lat pfd - „ 106 1071/2 2d pfd — — 761/2 ._ National Cap. Bank (Washington) __ __ 224 National Carbon, com — — 118 120 preferred *116 National Cash Register, pfd — __ *129 National City Bank (Baltimore) 110 National City Bank (Brooklyn) _. „ __ 275 295 National City Bank (Chicago) ._ __ 195 199 National City Bank (Cleveland) — >_ 235 255 National City Bank (Indianapolis) __ __ 151% I521/2 National City Bank (Memphis) __ __ 120 122 National City Bank (New York) — __ __ 450 National City Bank of Seattle _- __ 140 150 National City Bank (Troy) __ _. 172 175 National City Bank (Waco) __ — 95 105 National Commerce Bank 164 National Commercial Bank (Albany) __ 345 355 National Commercial Bank (Cleveland) ^160 National Cop. Bank (Salt Lake City) __ __ 139 140 National Enam. & Stpg., com 15% 15% preferred __ __ 87 93 National Exchange Bank (Augusta) 135 140 National Exchange Bank (Baltimore) «_ __ 161 163 National Exchange Bank (Hartford) $83 National Exchange Bank (Milwaukee) __ __ 212 214 National Exchange Bank (Providence) __ __ 255 280 National Exchange Bank (Wheeling) __ __ 223 225 National Fire Insurance (Hartford) __ __ 375 385 National Fire- Proofing, com __ __ $6% $7 preferred __ __ $28% $281/0 National Fuel Gas __ __ __ 164% National Gas, Electric Light & Power, com __ __ 30 preferred __ __ 80 National Glass Brick ^6 ^6 National Grocer, com _« __ 42 431/2 preferred __ __ 74 77 National Howard Bank (Baltimore) __ __ $141/2 $151/2 National Insurance (Hartford) __ __ 375 385 National Lead, com ^_ __ 50 52% preferred __ __ 105 107 National Lettergraph, pfd __ __ __ *25 National Licorice, com. *38 •Quotation nearest March 1, 1913. No quotation on that date. 1054 High Low Bid Asked National Light, Heat & Power, com „ — 8 preferred — — 46 52 National Machine ~ — ?15 National Machine Recorder Co . — — — — *^Y2 National Marine Bank (Baltimore) '.— — — 43 44 National Metal Bank (Washington) — — 205 210 National Mining — — ~ 1 National Nassau Bank of New York — — — *215 National New Haven Bank — — 193 National Newark Banking — — 195 National Pacific Oil — — 4y8C __ National Park Bank (New York) __ „ 367 373 National Produce Bank (Chicago) __ __ 159 163 National Produce Co. (Chicago) __ — *165 National Protection Co — — — *60 National Railways of Mexico, 1st pfd __ — 57 60 2d preferred — — 241/2 25 National Realty, Ltd — — 6 National Refining, com — — 121 preferred — — 126 National Reserve Bank (Kansas City, Mo.)-- — ~ 152y3 153^/^ National Reserve Bank (New York) __ — 93 97 National Rock Bank of Roxbury (Boston) __ __ 190 National Savings & Trust (Washington) __ __ 265 275 National Screw & Tack, pfd *100l^ __ National Security Bank (Boston) .___ __ __ 400 450 National Security Bank (Philadelphia) *350 *350 National Shawmut Bank (Boston) __ — 240 242 National Siik Dyeing, pfd __ ^94 National State Bank (Burlington) 250 National State Bank (Camden) *200 "200 National State Bank (Newark) 115 National State Bank of Troy __ __ 210 215 National State & City Bank (Richmond) __ — 218 National Sugar Refining, pfd __ __ 100 101*4 National Surety (New York) _- __ *198 *205 National Telephone Corp., pfd *27y2 *27y3 National Tradesmen's Bk. (New Hampshire). __ __ • 193 National Transit __ __ $49y2 $50y3 National Trust (Canada) *222 National Union Bk. of Maryland (Baltimore) __ __ 143 144 National Union Bank (Boston) 222 222 National Union Bank (Reading) __ __ $160 $165 National Union Insurance (Washington) $6 National Water Co., pfd ._ __ *67 common *7 Nationale, La Banque (Canada) 140 143 Natomas Co. of California IIV2 Naumkeag Steam Cotton (Massachusetts) *157 Naumkeag Trust (Salem) 250 Nebraska National Bank (Omaha) __ __ 115 130 Neuralgyline Co. 156 Nevada Consolidated Copper $17y2 $17l^ Nevada Hills Mining (Nevada) $1.15 $1.15 Nevada Utah M. & S __ __ 2c 5c Neversink Bank (Reading) __ __ $65 $70 New Arcadian Copper __ __ 2 2*^ New Baltic Copper __ __ 85c $1 New Bedford & Onset Street Railway ^_ 70 •Quotation nearest March 1, 1913. No quotation on that datt. 1055 High Low Bid Asked New Bedford (Massachusetts) Deposit & Tr._ __ __ 250 260 New Bedford Gas & Electric Light — — SOSVg — New Britain Machine — — $69 New Brunswick Trust — — 250 265 New Central Coal Co. of West Virginia „ __ *$10 *$15 New Departure Manufacturing, com __ __ $165 $175 preferred — — $105 $107 New England Co — — 153 154 New England Cotton Yarn, com __ __ — $70 preferred — — $86% $87 New England Engineering Co __ — — *91 New England Exploration Co __ — *2 New England Inv. & Sec, pfd._- — — *90 *92 New England Nat'l Bk. (Kansas City, Mo.) __ _. „ 450 475 New England Power, pfd *96 *96 • common — — — *38 New England Telephone & Telegraph __ __ 153 New England Trust (Boston) „ — 350 New First National Bank (Columbus, O.) — — 230 250 New Haven Gas Light __ — $411/3 $42ya New Haven Iron & Steel *40c New Haven Co. National Bank (New Haven) __ „ $20^4 — New Haven Water __ — $87 $89 New Haven Sewing Machine — — — *98 New Idria Quicksilver Mining — — 6 New Jersey Guarantee & Trust (Jersey City) 620 New Jersey Zinc __ __ 620 550 New London & Northern Railroad *200 *200 New Netherland Bank (New York) __ __ 220 New Orleans Auction Ex 310 New Orleans Board of Trade __ __ 25 50 New Orleans Brewing, com 40 preferred 47 New Orleans Cold 'Storage & Warehouse 75 New Orleans Cotton Exchange __ — — 3000 New Orleans Land __ __ 26 27Vj New Orleans Mobile & Chicago, pfd __ 15 25 • common 13 NcAV Orleans National Bank __ __ 175 New Orleans Railway & Light, com 31*/^ preferred __ __ 72^/2 — New Orleans Real Estate, Mtge. & Security 96 New Orleans Traction & Light, com 71% __ preferred *101 New Pennsylvania Petroleum __ __ 42y2C — New River Co., pfd __ __ __ *24 New York Air Brake 72 77 New York, Brooklyn & Manhattan Beach, pfd. __ __ *110 118 New York Central & Harlem River IO614 106*4 New York, Chicago & St. Louis, com __ __ 55 57 Ist preferred 97 • 2d preferred __ __ SOVi 90 New York County National Bank (New York) __ __ *850 875 New York Curtain Co __ __ __ *64 New York Dock, com __ __ __ 19 preferred 33 43 New York & East River Fer _, _, 8 15 "Quotation nearest March 1, 1913. No quotation on that date, X056 High Low Bid Asked New York & Harlem, com. gtd — — *$175 *$180 New York Iron Roofing & Corrugating __ „ — *350 New York & Kentucky Co., pfd — — — 95 common — — 84 85 New York, National Bank of — — — *390 405 New York, Lackawanna & Western, gtd __ — ^^118 133 New York Life Insur. & Tr. Co. (New York). __ — *1040 1065 New York Mortgage & Security — — 198 205 New York Mutual Gas Light Co „ __ *168 New York, New Haven & Hartford ISe^s l^eVg New York, Ontario & Western __ — 30 30ya New York & Queens Elec. Lt. & Power, com.> __ __ 53 58 preferred „ — ■ 78 85 New York Railways __ — *20 *30 New York & Richmond Gas __ — 57 63 New York State National Bank (Albany) __ __ 300 New York State Railways, com — *88 preferred __ __ *90 *93 New York Tanning Extract, pfd __ __ — *95 common __ *'^'^V» — New York Title Insurance __ — 105 115 New York Transit __ __ *335 *345 New York Transportation $5 $7 New York Trust (New York) __ __ 625 635 Newark Consolidated Gas __ __ 971/3 98% Newark Fire Insurance __ __ $14 Newark Telephone, com. 121 Newark Trust Co. __ __ 170 Newberry Cotton Mills (South Carolina)— __ __ 130 140 Newburyport Gas Light __ __ __ *200 Newburyport Silver Co. *100 *100 Newmarket Manufacturing (New Hampshire) *95 Newport & Fall River St. Ry. __ __ __ *110 Newport (Kentucky) National Bank __ __ 175 Newton (G. B.) Coal, com. __ __ 231/3 24% 1st preferred __ __ 98 100 2nd preferred __ *68 *75 Niagara Falls Power __ __ 165 173 Niagara Insurance (New York) __ __ $1571/3 $165 Niagara St. Cath, & Tor. *108 Nicholson File __ __ 265 283 Nichols & Shepard Co. __ __ *57 Niles-Bemont-Pond, com. 84 88 preferred 90 99 Ninth Avenue Railroad __ __ 160 180 Ninth National Bank (Philadelphia) *267 *267 Nipissing Mines __ __ 8% 8% Nonquitt Spinning Co. (New Bedford) 93l^ Norfolk & Nashville Steamboat __ __ 200 209 Norfolk Railway & Light __ __ $25% $361/3 Norfolk Southern __ __ 421/3 471/3 Norfolk (Virginia) Bank, Savings & Trust 455 465 Norfolk (Virginia) National Bank __ __ 190 193 Norfolk & Western, com. IO51/3 1051/, Norfolk & Western, adj. pfd. __ __ *89 92 North Alaska Salmon Co. __ __ __ 103 North American Co. 78% 78% North American Trading & Transportation *18Va North Atlantic Fisheries, Limited, pfd *100 *100 *QuotatldQ nearest March 1, 1913. No quotation on that date. 1057 High Low Bid Asked North Avenue State Bank (Chicago) __ 143 147 North Boston Ltg. Prop., pfd __ __ __ 128 North Boston Lighting Prop., com t33 North Butte Mining __ __ 2714 271/2 North Carolina Railroad __ __ 165 170 North Lake Mining __ __ 1% 2 North Memphis Savings Bank (Memphis) __ 450 500 North Pennsylvania Railroad *$94 North Philadelphia Trust *$106 *$106 North River Insurance (New York) __ __ $371/2 $40 North Scranton Bank (Scranton) __ __ $200 $205 North Side Bank (Brooklyn) __ __ 175 200 North Side Bank (Cincinnati) >. __ $170 $200 North Side St. Bank (Chicago) ^_ __ __ 115 120 North Star Mining (Nevada) 23c 22c North Ward National Bank (Newark) __ __ 395 Northampton (Massachusets Street Railway __ 118 120 North Bank & Trust (Seattle) __ __ 140 150 Northern California Power, Cons. 371/2 39 Northern Canadian Mtg., Ltd. , __ __ — *115 Northern Central Railway . __ __ $121 $123 Northern Crown Bank (Winnipeg) 96 97 Northern Idaho & Montana Power, com — 2 4 preferred 30 40 Northern Indiana Gas & Electric, pfd. __ __ *82 *86 Northern Insurance (New York) — — 90 110 Northern Liberties Gas *41 *41 Northern Life Insurance __ — *127y2 Northern National Bank (Duluth) __ __ 130 Northern National Bank (Lancaster) 130 132 Northern National Bank (Philadelphia) *206 *206 Northern National Bank (Toledo) 154 Northern Ohio Light & Traction, com. — — 75 preferred __ — — 105 Northern Ohio Traction __ _> 73 77 Northern Ontario Light & Power, com. __ — 16 20 preferred — __ 59% 62 Northern Pacific 116 1151/2 Northern Pipe Line — __ *112 *115 Northern Railroad (New Harashire) __ __ 128 130 Northern Railroad of New Jersey — __ 81 90 Northern St. Louis Trust — — 125 preferred — 30 40 Northern Securities — __ 105 110 Northern Star *22 *21i/2 Northern States Power, com. — — 2314 241/2 preferred __ __ 84Vi 851/2 Northern Texas Electric, com. __ __ 105 111 preferred — — 97 Northern Trust Co. Bank (Chicago) __ — 332 338 Northern Trust (Philadelphia) *450 •450 Northern Trust & Savings (Lancaster) __ __ $125 $127 Northwest F. & M. Insurance (Minnesota)— __ — 199 207 Northwest National Bank (Minneapolis) __ — 285 300 North West St. Bank ._ — 198 202 N. W. States Port. Cem., com __ — 15 25 preferred — — 84 90 Northwestern Bank (Philadelphia) '390 *390 — ^ __ •Quotation nearest March 1, 1913. No quotation on tliat date. t"Value" as of March 1, 1913. 1068 High Low Northwestern Power, com. preferred Northwestern Savings Bank (St. Louis) North Western Teleg. — North Western Trust (Philadelphia) *$185 *$185 Northwestern Trust & Sav. Bank (Chicago) Norwich & Worcester, pfd. *195 *195 Nova Scotia, Bank of (Canada) Nova Scotia Car Works, 1st pfd. *7.44% basis Nova Scotia Clay Works, pfd. *7.52% basis Nova Scotia Steel & Coal, com. — — 80 • preferred 123 120 Oakland (California) Bank of Savings __ __ 200 Oakland Park Land Co. *1 'l Occidental Life Insurance Occidental Mining (Nevada) Ogden Mine Railroad Ogilvie Flour Mills, com. preferred . _•___ Oglethorpe Savings & Trust (Savannah) Ohio Copper % % Ohio Fuel Oil Ohio Fuel Supply Ohio National Bank (Columbus, Ohio) Ohio Oil . Ohio Petroleum Co. Ohio Savings Bank & Trust (Toledo) Ohio Traction, com. preferred Oil Fields of Mexico Ojibway Mining 0. K. (Colorado Springs) Oklahoma Natural Gas Oklahoma State Bank (Guthrie) Old Boston National Bank (Boston) Old Colony Copper Old Colony Railroad Old Colony Trust (Boston) Old Colony Trust & Savings Bank (Chicago) Old Detroit National Bank (Detroit) Old Dominion Co. Old Dominion Tr. Rcpts. Old Dominion Steamship Old Gold (Colorado Springs) Old National Bank (Grand Rapids) Old Second National Bank (Bay City) Old South Bldg. Association Old Town National Bank (Baltimore) Olinda Land Co. » Olive Branch (Colorado Springs) Oliver Bldg. Trust (Boston) Omaha & Council Bluffs St. Ry., com. preferred Omaha & Council Bluffs St. Ry. & Bdge., com. Omaha Electric Light & Power, pfd Omaha National Bank Omaha Stock Yards Oneco Copper Mining Oneida National Bank (Utica) ^Quotation nearest March 1, 1913. No quotation on that date. 1059 Bid Asked 8 45 295 300 ^$581/2 *$60 268 272 2601/4 261 125 140 70c 100 123 127 120 1671/3 — *$16% *$17 $451/8 275 285 $123 ! $125 *25 140 39 45 70 85 IVa 1% 2 2y4 .0050 691/jj 70 125 125 127 sy^ 6 175 330 340 117 120 194 200 48 481/2 5 7 103 107 21/2C 3c 208 212 125 $65 $121/2 $14 391/2C 002 $101 68 __ 82 •631/2 ♦85 175 200 ♦96 1% 1% 225 235 High Low Oneida-Regal Textile, pfd. Onomea Sugar Co. Ontario Loan & Deb. *172 Ontario Power Ontario & Quebec Railway Ontario Silver Mining Co. Ophir Silver Mining (Nevada) Orangeburg Manufacturing, pfd. Oro Electric Corporation, com. preferred Oro Mining (Nevada) 12c 12c Oro Water, Light & Power Co O'Rourke Eng. Constr. Orr Cotton Mills (South Carolina) Osage & Oklahoma Gas *61 'CI Osborn Mills (Fall River) Osborn Paper Co., pfd. *26 *26 Osceola Consolidated Oswego & Syracuse . Otis Elevator, com. preferred Otis-Fenson Elevator, Limited, pfd. *100 *100 Ottawa, Bank of (Canada) Ottawa Light, Heat & Power Ottumwa (Iowa) Railway & Light, pfd. Overman Mining (Nevada) Owens Bottle -Machine Owisso Sugar Co. Oxford Linen Mills, "A" stk. "C" stk. Oxweld Acetylene Co. Ozark Power & Water Co Paauhau Sugar Plan Pabst Brewing, pfd. Pacific & Atlantic Teleg. Pacific Aux. Fire Al. (San Francisco) Pacific Bank (New York) Pacific-Burt Co., com. preferred Pacific Coast Borax, com. preferred Pacific Coast Casualty Pacific Coast Co., com. 1st preferred 2nd preferred Pacific Crude Oil Pacific Gas Electric (Arizona), pfd. Pacific Gas & Electric (California), com. Pacific Gas & Electric (California), orig. pfd. Pacific Insurance (New York) Pacific Lighting, com. preferred Pacific Mail Steamship Pacific Mills (Massachusetts) 1^2y4 Pacific Mutual Life Insurance Pacific National Bank (Lawrence) Pacific National Bank (Tacoma) Pacific Power & Light, pfd. 'Quotation nearest March 1, 1913. No quotation on that date. 1060 Bid Asked n02i/a 32 83 841/2 142 145 2V2 3 18c 20c 75 143/4 1534 — 721/4 100 •85 90 100 — 1121/2 $86 $87 $1021/2 $110 82 83 98 100 207 y_ 1861/2 90 921/2 20c *445 •73/4 *3 __ *13/4 *83 *48 *53 16% 107 110 $161/2 $181/2 4ya $178 * $133 39 _ 90 80 1001/2 101 115 127 80 95 80 100 80 100 45c 50c 87 90 58% 593/4 89 SlVa $433/4 108 115 743/4 __ 26 28 425 600 120 275 100 103 High Low Bid Asked Pacific Smelting & Mining ^ 7-33 Pacific Tel. & Tel. Co., com. _ 861/2 39 • preferred ^__ __ __ 92 100 Package Machinery, pfd. *100 Packard Motor, pfd. __ 104 Packers National Bank (So. Om.) __ __ 110 135 Pacclet Manufacturing (South Carolina) __ __ 98 103 Paddock Trust (Boston) __ _. $90 Paducah Tr. & Lt., com. __ __ 7 10 preferred — __ 30 Page Manufacturing (New Bedford) 96 Paint Creek Colleries, stk. rets. __ — *8 *9 Pairpoint Corp. (New Bedford) __ __ 175 325 Palmer Oil __ __ 15c Pangborn (T. W.) Co. '11 *11 Park Bank (Los Angeles) __ __ 115 135 Park National Bank (New York) __ __ 360 Park National Bank (Holyoke) __ »_ 100 105 Parke, Davis & Co. __ __ 119 Parker Cotton Mills, com. __ 15 20 guaranteed __ 90 98 preferred __ __ 55 60 Parker Mills (Fall (River) __ ._ __ 75 Passaic (New Jersey) National Bank 310 Passaic Trust & Safe Deposit __ __ 225 Paterson & Pas. G. & El. __ __ 921/3 95 Paterson National Bank __ __ 310 Paterson Safe Deposit & Trust __ __ 360 400 Paterson Savings Institution (Paterson) 370 380 Paton Manufacturing 691/3 Pawtucket Gas, pfd. __ __ 89 94 Pay-As-You-Enter Car, pfd. _> __ *40 *46 Pearl St. Market Bank (Cincinnati) __ __ 105 115 Pearl St. Savings & Trust (Cleveland) >_ _> $275 Peck, Stow & Wilcox, com. __ -_ $331/3 $36 • preferred *100 Peerless Motor Car, pfd. *100 *100 Pelham Trust (Philadelphia) *$130 *$130 Pelzer Manufacturing Co. (South Carolina) 130 Pem'ton Bldg. Tr. (Boston) __ __ __ $60 Pemigewasset Valley Railroad *110 *110 Penguico Mines, pfd. __ __ *11 *15 Peninsular State Bank, Detroit __ 210 Penmans, Limited, com. 54 55i^ ■ preferred — __ __ 84 Penn Metal Ceiling __ __ __ *300 Penn National Bank (Philadelphia) *$192i4 *$192i4 __ Penn National Bank (Reading) __ __ 325 329 Penn Traffic — — $1% _. Pennsylvania Academy of Fine Arts *19 *19 Penn. Co. for Ins. on Lives & Grtg. An *$645 *$645 Pennsylvania Fire Insurance (Philadelphia) $40614 Pennsylvania Lighting, com. __ __ 18 21 preferred — __ 75 80 Pennsylvania Midway Oil — __ 71/3C __ Pennsylvania Railroad $60 $59% Pennsylvania Salt Manufacturing __ __ $1051/3 $106 Pennsylvania Steel, com. — 5( -preferred 93 •Quotation nearest March 1, 1913. No quotation on that date. 1061 High Low Bid Asked Pennsylvania Textile __ __ 24 26 Pennsylvania Trust (Reading) — __ 500 Penn. Whg. & Safe Dep. (Philadelphia) *$86i4 $8614 Pennsylvania Water & Power __ __ 65 66 Pennsylvania Wire Glass •46ys •46y8 Pensacola Electric Co., com. . __ 23 28 preferred __ __ 82 85 People's Bank (Buffalo) >_ __ 200 People's Bank (New York) ._ __ *$60 *$62i/2 People's Bank (Troy) __ _. 210 215 People's Bank (Wheeling) __ __ $33 $35 People's Bank (Wilkesbarre) __ __ 340 350 People's Bank & Savings (Cincinnati) __ 110 120 People's Bank & Trust (New Haven) __ __ 145 People's Bank & Trust (Passaic) __ — 290 300 People's Gas Light & Coke 111% III8/4 People's National Bank (Barre, Vt.) __ __ 105 People's National Bank (Brooklyn) 145 155 People's National Bank (Charleston) __ 145 150 People's National Bank (Kansas City, Kan.)- — -- 95 100 People's National Bank (Lancaster) 185 190 People's National Bank (New Brunswick)— __ __ 250 275 People's National Bank (Scranton) __ __ IGGi/o 1691/2 People's National Bank of Roxbury (Boston) __ __ 125 130 People's National Fire Insur. (Philadelphia) $181/3 __ People's Nat. Gas & Power __ __ __ $31 People's Safe Deposit & Trust (Jersey City) __ __ 325 People's Savings Bank (Bay City) 150 People's Saving Bank (Cleveland) — __ $220 People's Savings Bank (Grand Rapida) __ 250 People's Savings Bank (Saginaw) __ __ 260 270 People's Savings Bank (Wilmington, N. C.)-_ — „ $18% $20 People's Savings Bank & Trust (Covington) __ __ 120 People's Saving Bank & Trust (Memphis) ___ __ __ 205 215 People's State Bank, Detroit __ _. 271 280 People's Stock Yards St. Bk. (Chicago) __ __ 240 250 People's Trust (Brooklyn) __ __ 295 305 People's Trust (Lancaster) $300 People's Trust (Philadelphia) ♦$45 •$45 People's Trust & Savings Bank (Chicago) __ __ 300 310 People's Water Co., com. 4 4% People's Water Co., pfd. __ __ __ 60% Peoria & Bureau Vy. __ __ 165 178 Peoria & Eastern __ __ 11 15 Pepperell Manufacturing (Maine) 304% Pequonnock National Bank (Bridgeport) 165 Peregrina Mining & Milling, pfd. *12 *1Q Pere Marquette, com. 3 6 1st preferred __ __ 14 18 2nd preferred __ __ 6 11 Perkins (Rhode Island) Horse Shoe, pfd __ __ *50 Petersburg (Virginia) Savings & Ins __ __ __ $100 Pettibone Mul., com. 26 35 1st preferred __ __ 92 96 2nd preferred __ . __ __ *83 Pfandler Co., pfd. __ __ __ •130 Pharmacist (Colorado Springs) __ __ li^e 2%c Phelps-Dodge & Co __ ._ 200 Phenix National Bank (Providence) __ __ $105 ♦Quotation nearest March 1, 1913. No quotation on that date. 1063 High Low Bid Asked Phil Carey, pfd. __ ._ lOOVa 105 Philadelphia & Trenton Railroad 240y2 __ Philadelphia Bourse, pfd. ,___ *$4 *$4 common *$1 *$! Philadelphia City Passenger Railway *$156y3 Philadelphia Co., com. $44% $45% 6% preferred $39% $451/2 5% preferred $38 $441/2 Philadelphia Electric __ __ $22% $231/3 Philadelphia & Erie *$65 • __ Philadelphia, Germantown & Norristown __ __ $142 $145 Philadelphia & Gray's Ferry Pass. Ry *$80i4 __ Philadelphia Life Insurance $10l^ __ Philadelphia Mortgage & Trust *15 *15 Philadelphia National Bank ♦478 *478 Philadelphia Rapid Transit, vot. tr. ctfs __ $25% $26 Philadelphia Traction $83% $83 Philadelphia Trust, Safe Deposit & Ins. Co.- *741i/4*741% Phillipine Tel. & Tel. __ __ 2414 __ Phillips Buttorff Manufacturing __ 140 145 Phoenix Third National Bank (Lexington) __ __ 163 163 Phoenix Fire Insurance (Hartford) __ 330 340 Phoenix Insurance (Memphis) 96 100 Phoenix Insurance (Memphis) __ 96 100 Phoenix National Bank (Hartford) __ __ 155 161 Physical Culture Restaurant __ __ *4 Piedmont Manufacturing (South Caroclina) 175 Pierce, Butler & Pierce Manufacturing, pfd.__ __ 101 104 Pierce Manufacturing (New Bedford) 340 Pinelawn Cemetery Co. *3l^ Pioneer Trust (Kansas City, Mo.) 250 260 Pittsburgh, Bessemer & Lake Erie, com. __ __ $29 $32 preferred __ $62 $68 Pittsburg Brew., com. __ $10 $101/3 preferred $37% Pittsburgh -Buffalo Co., pfd. __ __ 125 Pittsburgh, Cine, Chic. & St. Louis, com __ __ 96% 97 preferred 100 115 Pittsburgh Coal, com. 21% 21% ' preferred 87% 88 Pittsburgh, Ft. Wayne & Chicago, gtd. _- __ ♦161 *163 special guaranteed ^148 *156 Pittsburgh Insurance $86 Pittsburgh & Lake Erie __ __ $195 $205 Pittsburgh, McKeesport & Youghiogheny, gtd. ♦$62l^ Pittsburgh Oil & Gas __ __ $7% $8 Pittsburgh Plate Glass __ __ 101 102 Pitts. Silver Peak Gold Mining, (Colorado) __ 60c 60c Pittsburgh Spring & Steel __ __ *100 *130 Pittsburgh Steel, pfd. __ __ 95 100 Pittsburgh Trust __ __ __ ^200 Pittsburgh, Youngstown & Ashtabula, pfd. ^162 ^167 Pittsfield Electric __ __ __ t200 Plant (Thomas G.) Co., pfd. __ __ __ ♦lOl Planters* Loan & Savings Bank (Augusta) $40 $45 Planters' National Bank (Richmond) 800 Plimpton Manufacturing 120 124 Plymouth Cordage Co. __ __ __ ♦237l^ Plymouth Rubber, pfd. ♦lOO •100 •Quotation nearest March 1, 1913. No quotation on that date. fValue" as of March 1, 1913. 1063 High Low Bid Asked Pneumatic Scale Corporation, Limited, pfd.__ *$10y2 *$10y2 common __ *5 Pocasset Manufacturing (Fall River) __ __ __ 108 Poe (F. W.) Manufacturing (South Carolina) __ __ 105 115 Pomeroy Ink Co. (New Jersey) *$1 *$1 Pond Creek Coal __ __ 23% 24 Ponemah Mills (Providence), com. __ __ 109 preferred __ __ 108 112 Pope Manufacturing, com. $22 $25 ■ preferred $68 Porcupine Gold Mines __ __ 15c 20c Porcupine Twins Mining *8c *8c Portland (Maine) Electric Co., pfd. *100 *100 Portland Gas & Coke, pfd. __ __ 101 103 Portland (Maine) Gas Light __ __ $95 $100 Portland Gold Mining __ __ 98c $1 Portland (Maine) National Bank __ __ 170 180 Portland Railroad __ __ __ *115 Portland Railway, Light & Power, 1st pfd._- __ __ 67 . 68y2 Porto Rican -American Tobacco __ -_ 240 250 Porto Rico Railways, com. __ __ __ *72 preferred *110 Postal Life Insurance Co. __ __ *8 Potomac Fire Insurance 30 Potomac Insurance (Washington) $30 Potomska Mills (New Bedford) __ __ __ 119 Potosi Mine (Nevada) 2c 2c Prairie Oil & Gas _. _- *327 *330 Pratt & Cady __ __ __ $96 Pratt & Whitney, pfd. „ __ 101 103 Pratt Read Co. __ __ *90 *105 Pray Bldgs. Tr. (Boston) __ __ __ $30 Premier Oil __ __ 25c 31c Pressed Steel Car, com. 27 26% • preferred 971/2 97 Preston East Dome Mines __ __ 3c 5c Price Brothers — 73 Price Cereal Prod., pfd. •lOO *100 Procter & Gamble, com __ __ 550 600 preferred 190 Produce Exchange Bank (Kansas City, Mo.) 160 Produce Exchange Bank (New York) __ „ 168 173 Producers Oil „ __ 130 Producers Transportation 90 Proprietors of Revere House (Boston) •I 75 *175 Providence Bank (Scranton) __ __ *105 *107V3 Providence Gas — __ $100 $104 Providence Ice Co., pfd. — *58 Providence (Rhode Island) National Bank 217 Providence National Bank (Waco) __ __ 215 Providence Telephone — — $5iy2 $53% Providence, Warren & Bristol Railroad „ __ 145 Prov. Wash. Ins. (Providence) >_ __ $83 $90 Providence & Worcester __ __ 270 275 Provident Life & Trust (Philadelphia) *875 •875 Prov. Savings Bank & Trust (Cincinnati) _._ __ __ $23y2 $24 Prudential Life lisurance __ __ $262y2 __ Public Service Co., Nor. 111., com. __ __ 80 81 ^preferred — — 98 99 ♦Quotation nearest March 1, 1913. No quotation on that date. 1064 High Low Bid Asked Public Service Corporation of New Jersey __ __ 116 119 Public Service Investment Co., pfd. *5.95% basis Public Utilities, com. '. __ __ $50 ■ preferred __ __ $48 $52 Pueblo Smelting & Refining 2^ 2 Puget Sound Traction, Light & Power, com. 65 67 ■ — ^preferred __ __ 107 108 Pullman Co. USYz 1581/2 Pullman Trust & Savings Bank (Chicago) __ 180 Pure Oil __ __ $15*4 $151/3 Puritan Trust (Boston) __ __ 200 Pyle National Electric Headlight „ __ *105 Quaker City National Bank (Philadelphia) __ "120 *120 Quaker Oats, com __ __ 265 270 ■ ^preferred __ __ IO6I/2 IO71/2 Quarter Savings Bank (Wheeling) __ 150 Quebec Bank (Canada) 125 Quebec Railway, Light, Heat & Power __ __ 18l^ 18% Queensboro Corporation, pfd. *100 common __ __ _> *95 Queensboro Development Co - '116 *116 Queensbury Mills (Massachusetts), com. 175 200 preferred __ __ 115 117l^ Queens County Trust (Jamaica) __ __ 100 110 Quicksilver Mining, com. 3% 4 ■ ^preferred 4 7 Quincy Electric Light & Power __ __ __ t200 Quincy Mark. R. E. Tr. (Boston) __ ._ $100 $103 Quincy Mining __ _. 661/2 67% Railway Steel-Spring, com 29 29 preferred __ __ 981/2 100 Railways Co. General _> __ $9 $91^ Raleigh (North Carolina) Banking & Trust__ __ 125 Raven & B. Hill (Colorado Springs) __ __ 6c 71/2C Raven Copper 16c 20c Rawhide Coalition Mining (Nevada) Ic Ray Consolidated Copper $18 $17% Reading Co., com. $78% $78 1st preferred __ $45 $45l^ 2nd preferred __ __ $44l^ $45l^ Reading National Bank 275 285 Reading Traction __ $25 $30 Reading Trust __ _- 205 210 Real Estate Assoc. (Boston) $85 Real Estate, Banking & Trust (Savannah) __ __ __ 137 138l^ Real Estate Loan & Savings '100 Real Estate Title Insurance — 95 Real Estate Title Ins. & Trust (Philadelphia) *300 *300 Real Estate Tr. (Philadelphia), pfd. '61 *61 , __ common *96i/8 *96% Real Est. Trust (Pittsburgh) „ __ __ 155 Realty Assoc, of Brooklyn __ $110 $115 Realty Realization, pfd. — __ __ *90 Realty Syndicate — — 1331^ __ Red Hills Mining (Nevada) __ Ic 2c Red Top Extension Mining (Nevada) __ __ Ic Reece Button-Hole — — $15 $15% "Quotation nearest ^iJircji 1, 1913. No quotation on that date. t"Value" as of March 1, 1913. 1065 High Low Reece Folding Machine Reed-Prentice Co., pfd. Regina Lace (Rhode Island) Reliance Insurance (Philadelphia) $83 Remington Typewriter, 1st pfd. 2nd preferred common Renfrew Manufacturing, pfd. Rensselaer & Saratoga Reo Motor Car Co. 1 Reo Motor Truck Co. Republic (Colorado Springs) Republic Iron & Steel, com. ■ preferred Republic Railway & Light, com. preferred Republic Trust (Philadelphia) *$66 *$66 Requa Savage Rescue Eula Mining (Nevada) 13c 13c Revere Sugar, pfd. Reynolds (R. J.) Tobacco Rhode Island Coal Rhode Island El. Protect. Rhode Island Hosp. Tr. (Providence) Rhode Island Perk. Horse S., pfd. Rhode Island Safe Deposit Rice Ranch Oil Richelieu & Ontario Navigation Richmond Bank & Trust Richmond, Fredericksburg & Pot. Div. Oblig. common 6% guaranteed 7% guaranteed Richmond, Fredericksburg & Potomac, and Richmond & Petersburg Railroad and Connection Co. ($70 par) Richmond Lace Works Ridge Avenue Bank (Philadelphia) *$60 *$60 Ridge Ave. Pass. R. R. *$245 Riggs National Bank (Washington) Riker-Hegeman, com. Rio Grande Southern Rio Plate Mining Rittenhouse Trust (Philadelphia) ♦$55 *$55 Ritter (W. M.) Lumber, pfd. Riverside Home Tel. & TeL Riverside Trust (Hartford) Rivett Lathe & Grinder, pfd. Roanoke (Virginia) Gas Light, pfd. common Roanoke Mills (North Carolina) Rochester & Genesee Valley Railroad Rochester Railway & Light, pfd. Rochester Trust & Safe Deposit , Rock Island Co., com. 22% 22% preferred 38 38 Rockford Electric, pfd Rockford Life Insurance Co. Rockport Granite •31^4 •3I14 ^Quotation nearest March 1, 1913. No quotation on that date. 1066 Bid Asked 31/2 474 *6.80% basis ~ 1021/8 *99 •looy. *99 *100i/a *39i/2 *4oy8 ♦1071/, ♦178 ♦183 201/3 21% ♦i2y. .005 .007 24 25y4 851/2 87 26 28 77 80 — 3c " ♦100 265 268 5c 10c 130 3350 55 110 1.10 113% 114 $271/2 320 330 320 330 320 330 320 330 115 120 — ♦95 580 605 ♦75 5 10 ♦40 ♦80 ♦103 "■" 18 160 •100 ♦85 ♦15 ♦20 160 115 93 95 400 — ~ ♦96 ♦17 High Low Bid Asked Rogers (Wm. A.) Limited, com. 170 preferred __ __ __ 115 Rome & Clinton Railroad __ 130 145 Rome, Watertown & Ogdensburg '. *120 Rose Niehol (Colorado Springs) __ __ .006 Roseville Trust (Newark) __ __ 175 Ross Mining & Milling *5e *5c Rotary Ring Spinning 1 li^ Round Mountain Mining (Nevada) 45c 35c Royal Baking Powder, com. __ __ 200 205 preferred 105 108 Royal Bank of Canada 222 Royal Weaving Co, __ __ *155 Rubber Goods Manufacturing Co., pfd. __ *100 *110 Rugby Fuel Co. __ __ __ ♦45 Rumely (M.), pfd. 92 92 common __ 71 72^3 Russell Motor Car, com. __ __ 90 preferred __ __ __ 971/2 Rutland County National Bank 133 Rutland Railroad, pfd. __ __ 49 Rutland (Vermont) Trust __ __ 200 Saco-Lowell Co., com. 200 ■ preferred __ 107 109 Safe Deposit & Trust of Baltimore __ 600 Safe Deposit & Trust (Pittsburgh) __ __ __ 290 Safety Car Heating & Lighting, com 114l^ II5I/3 Safety Fd. National Bank (Fitchburg) __ __ 165 170 Sagamore Mills (Fall River) __ __ __ 175 St. Anthony Falls Bank (Minneapolis) 150 St. Ives Mining (Nevada) __ __ 30c St. James Importing Co. *3 St. John Railway *75i4 __ St. Joseph & Gr. Island, com. __ __ *18 Ist preferred *50 2nd preferred __ __ *36 St. Joseph Lead __ __ 8% 8% St. Joseph Ry., Light, Heat & Power __ __ __ 90 common __ 53% __ St. Lawrence & Chicago Steam Navigation.. __ __ 108 110 St. Lawrence Flour Mills, Limited, pfd *100 *100 St. Lawrence Milling, pfd *100 *100 St. Louis Bridge, 1st pfd. __ __ 110 123 2nd preferred 50 55 St. Louis Car Co., pfd. __ __ __ *51 St. Louis Catering, pfd. __ __ __ 1914 St. Louis Cotton Compress __ __ 37 40 St. Louis Mining (Nevada) __ __ 2c St. Louis, Rocky Mountain & Pacific, com. 20 35 preferred — 55 60 St. L. & S. F., 1st pfd. 59 56 2nd preferred 24% 24% common __ __ 13 16 St. Louis Southwestern, com. __ __ 30 34% preferred — __ __ 73l^ 75 St. Louis Union Trust __ __ __ 477 St. Mary's Mineral Land __ __ 38 St. Paul & Tacoma Lumber __ __ *115 *140 •Quotation nearest March 1, 1913. No quotation on that date. 1067 High Low Bid Asked St. Paul F. & M. Ins. — __ 420 St. Paul Title & Trust *$17l^ „ Salem (Massachusetts) Electric . __ 68l^ Salera (Massachusetts) Gas Light — — 250 Salem (Massachusetts) Safe Deposit & Trust — 150 Salmon Falls Mfg. (New Hampshire) '275 San Antonio Copper 5 San Diego Home Tel. & Tel. __ __ 5 San Joaquin Light & Power — — *15 San Francisco, Oakland Term. Rys., "A" pfd. __ __ __ 80 San Toy Mining *22c •22e Sanborn Map 'GS Sandstorm -Kendall Consol. Mines (Nevada) — 2e Sandusky Portland Cement, com. *20 ^preferred *90 Sanitol Chemical __ __ __ *2% Santa Cruz Portland Cement 45 Santa Fe Gold and Copper __ __ 1% 1% Santa Monica B. H. T., pfd. „ __ 9 Santa Ysabel Mining __ __ 2c 3c Saratoga & Schenectady Railroad 160 170 Sauer Dough __ __ $1.40 Savage Mining (Nevada) __ __ 3c 4c Savannah Bank & Trust „ — 1721/2 __ Savannah Electric, com. — — 8 preferred 25 Savannah Trust Co. >- __ 143V8 — Savings Bank (Richmond) — — $94 Savings Trust (St. Louis) __ __ 105 110 Sav. Un. Bk. & Tr. (San Francisco) „ __ 245 Savoy Oil — __ M *5y8 Sawyer Massey Co., com. __ __ 481/2 ^preferred — — 90 Scandinavian- American Bank (St. Paul) — — 220 Scandinavian- American Bank (Seattle) — 250 255 Scandinavian- American Bank (Spokane) — 115 120 Scandinavian -American Bank (Tacoma) __ — 105 Scandinavian-Amer. Nat. Bank (Minneapolis) __ 148 Schuylkill Valley Bank (Reading) __ __ $150 $153 Scientific American Compiling Co., pfd *5 Scioto Valley Traction, 1st pfd. __ _« __ 100% 2nd preferred — 83 common __ __ 19*4 Scituate (Massachusetts) Water, pfd. 100 100 Scorpion Mining (Nevada) __ __ 5c 6c Scotten -Dillon Co. „ ._ __ •130 Scovill Manufacturing Co. __ __ __ ♦153 Scranton Bolt & Nut „ __ *103 '106 Scranton Electric, pfd. "lOO '100 Scranton Savings Bank __ __ 800 825 Seaboard Air Line, pfd. 44 44 common __ __ 19 19V8 Seaboard National Bank (New York) 415 Seaboard National Bank (Norfolk) __ __ 125 130 Seaconnet Mills (Fall River) __ __ __ 63 Seager Engine Co — — __ *10 Sears, Roebuck, com. 198 198 preferred — — 123 124% 'Quotation nearest ATarch 1, 1913. No quotation on that d&te. 1068 High Low Bid Asked Seattle National Bank — — 310 315 Second & Third Streets Pass. Ry. $250 Second Avenue Railroad — — 13 Second National Bank (Allentown) — — 320 330 Second National Bank (Altoona) __ — 200 210 Second National Bank (Baltimore) — — 200 Second National Bank (Bangor) __ — — 325 Second National Bank (Boston) __ — 290 300 Second National Bank (Hoboken) — — 390 Second National Bank (Lexington) — — 155 Second National Bank (New Haven) __ — 194 Second National Bank (New York) — — 200 210 Second National Bank (Paterson) — — 225 Second National Bank (Philadelphia) *290 *290 Second National Bank (Pittsburgh) *$195 *$1943/4 Second National Bank (Reading) __ __ 285 293 Second National Bank (Saginaw) — — *375 400 Second National Bank (Toledo) — — — 276 Second National Bank (Utica) __ — 200 225 Second National Bank (Washington) __ — 162l^ 170 Second National Bank (Wilkesbarre) „ __ 340 350 Sec. Sav. Bk. & Safe Dep. (Cincinnati) — — 200 205 Security Bank (Chicago) — — 235 Security Bank (New York) — — *133 140 Secur. Bank & Trust (Memphis) — — 100 105 Security Bank & Trust (Toledo) — — 134 Security Co. (Hartford) __ — 195 Security Insurance (New Haven) __ __ $43 $50 Security National Bank (Kansas City, Mo.) __ __ 130 140 Security National Bank (Minneapolis) __ — 492 510 Security Savings Bank (Charleston) — — 250 255 Security Savings Bank (San Francisco) __ __ $330 $375 Security Savings & Trust (Erie) __ — 170 Security Storage — — 210 Security Title & Trust (York) — __ $50 $52 Security Trust (Camden) __ — 270 275 Security Trust (Detroit) — — 255 Security Trust (Harrisburg) — — $33 $37., Security Trust (Hartford) __ — 195 Security Trust (Indianapolis) — — 128*^ — Security Trust (Rochester) — __ 500 Security Trust (Troy) — — 200 205 Security Trust (Wheeling) __ __ 170 175 Seccurity Tr. & Safe Dep. (Wilmington, Del.) __ — 235 245 Security Trust & Sav. Bank (Los Angeles) __ __ 446 Seg-Belcher Mining (Nevada) — — 3c 6c Semet-Solvay Process — -- *130 Seminole Fruit & Ld. *13 *13 Seminole Manufacturing, com. — — 15 25 1st preferred — — 90 100 2nd preferred — — 40 50 Sen-Sen Chiclet *115% ~ Seneca Mining — — 27 40 Shannon Copper — — 11 lll^ Sharon Railway — — $54 Sharp Manufacturing (New Bedford), pfd.__ __ __ 105 107 Shattuck-Arizona Copper — __ 25 Shawinigan Water & Power — __ 136 138 Shawnee State Bank (Topeka) — _- . — 175 'Quotation nearest March 1, 1913. No quotation on that date. 1069 High Low Bid Asked Sheffield Farm s-SIawson -Decker, pfd __ __ *98i/o __ Sheldon Axle Co. __ ._ *100 *103 Sheridan Trust Savings Bank __ ._ 133 136 Sheriff St. Mkt. & Stge. __ __^ 60 70 Sherman National Bank (New York) __ __ 135 Sherwin-Williams, com. *240 6% preferred *110 • 7% preferred 123l^ __ Shredded Wheat, com. __ __ __ 82 ■ preferred 92% Sibley Manufacturing (Georgia) __ 52 57 Siegel Stores Corporation, com. 25 preferred __ __ 88 90 Sierra Nevada Mining (Nevada) lie lOe Sierra -Pacific Electric, com. __ *16 -preferred __ . __ __ *85i4 Silk City Safe Deposit & Trust (Paterson).. __ __ 220 Silver Hill Mining (Nevada) __ 4c 4c Silver King Consolidated Mining — — % 1 Silver Peak Mining '570 *57c Silver Pick Consolidated Mines (Nevada) 6c 6c Silversmiths Co. 96 Simpson Dry Dock — *35 Singer Manufacturing 295 300 Single Service Pkg. Corp., pfd — *25 Sioux City Stock Yards, com __ __ 20 25 preferred — __ 871/2 90 Sixth Avenue Railroad __ __ *115 *124 Sixth National Bank (Philadelphia) *200 *200 Skenandoa Cotton (Utica) __ __ 133 138 Slosa- Sheffield Steel & Iron, com. __ __ 35 43 preferred — — 9I1/2 98 Smart Bag, com. — — 120 Smith (John E.) Manufacturing, pfd. __ _- __ '100 Smyth Manufacturing __ __ 230 240 Snell & Simpson Biscuit, pfd. __ __ __ *97l^ Solar Refining — „ *640 *660 Somerset, Union & Middlesex Lt. 70 73 Soule Mills (New Bedford) „ __ __ 99 South Bend Life Assurance *11 South Carolina Light, Power & Rys., pfd "100 South Carolina Loan & Trust (Charleston)— __ 155 160 South Chattanooga Co. *100 *100 South Chicago Savings Bank (Chicago) __ 200 South End National Bank (Boston) __ __ 112 South Eureka Mining (Nevada) __ __ $2.50 South Jersey Gas & Elec. & Trac __ __ __ "130 South Lake Mining , __ __ 7 7% South Live Oak __ __ 13 South National Bank (Wilmington, N. C.)— __ — 155 160 South Penn Oil — — *945 ^960 South Porto Rico Sugar, com. __ __ *64i4 *69y2 preferred — — ♦IO414 •1081/3 South Shore Realty *60 *60 South Side Bank (St. Louis) * __ ' __ 375 South Side Bank (Scranton) __ __ $160 $170 South Side Bank (Wheeling) __ ._ $152 $175 South Side State Bank (Chicago) __ __ 130 135 South Side St. Bank (Minneapolis) __ __ 250 *Quotation nearest March 1, 1913. No quotation on tbat date. 1070 High Low Bid Asked South St. Trust (Boston) __ >. $100 South Term. Tr. (Boston) _« __ $70 $85 So. Tex. Com'l Nat. Bk. (Houston) __ ._ 310 325 South Utah Mines % % South West & B. Oil 16c 16c South West Penn Pipe Lines __ __ __ *173 South West Trust & Savings Bank __ __ 125 133 Southern & Atlantic Tel. __ __ $21^4 $23% Southern Calif. Ed., com. __ __ STVg 90 preferred __ __ 931/2 95 Southern Ice, pfd — — *81 Southern Loan & Savings Bank (Charlotte) 160 Southern National Bank (Louisville) 132 135 Southern New England Telephone __ __ 138 140 Southern Pacific 99% 99% Southern Pipe Line __ __ *255 *262 Southern Railway, com. 26 25% ' preferred SOi/g SOYs Southern Railway, M. & O. stk. tr. ctfs __ 77^4 Southern Trust (Little Rock) __ __ *27y2 — Southw'k National Bank (Philadelphia) *145i4 •145l^ — Southwestern Com'l & Sav. Bank (St. Louis) 219 S. W. Nat'l Bank of Com. (Kansas City, Mo.) — __ ISSVs 1891/2 Southwestern Miami Dev. 3 4 Southwestern National Bank (Philadelphia) *118 *118 Southwestern Power & Light, pfd. 97 100 Southwestern Railroad of Georgia 104 107 Southwestern Utilities, pfd. __ __ *31 -common *30 Spanish River Pulp, com. 67% 68 preferred 94 Spartan Mills (South Carolina) __ __ 110 120 Spearhead Gold Mines (Nevada) 3c 3c Spencer Heater, pfd. *90 *97Vi common *30 *50 Spitzer-Roe Tr. & Bk. (Toledo) __ __ 125 Spokane & East. Tr. (Spokane) __ __ 235 250 Spokane International Railway *53 Spokane Title __ __ __ "75 Spring House & Hillt'n Turnpike *41 *41 Spring Valley Water __ __ 62% 63% Springfield Avenue Trust (Newark) 120 Springfield Gas Light __ __ __ t280 Springfield (Ohio) Light, Heat & Power __ __ __ 571/3 Springfield (Massachusetts) National Bank 210 215 Springfield (Massachusetts) Safe Dep. & Tr. __ __ 225 232 Stafford Mills (Fall River) __ __ __ 921/, Standard Bank (Toronto) __ __ __ $1121/2 Standard Coupler, com. __ 35 40 preferred — 105 111 Standard Fabric Co. __ __ __ *105 Standard Fire Insurance (Hartford) $84 $90 Standard Gas & Electric, com. __ __ $16 $17% preferred __ __ $46i^ $48 Standard Heating & Ventilating, pfd. __ __ *100 *115 common — — — •llO Standard Loan Co. of Tor. __ *84 Standard Milling, com. 35 39 preferred — — 63% 66 •Quotation nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1071 Bid Asked •21/4 __ 1185 1220 700 800 *186 *188 *330 *335 *565 *580 ♦405 *420 *310 *340 *650 *660 *270 *280 High Low Standard Motor Construction Co. Standard Oil (old) Standard Oil (subsidiaries) Standard Oil of California Standard Oil of Indiana Standard Oil of Kansas Standard Oil of Kentucky Standard Oil of Nebraska Standard Oil of New Jersey 374 371 Standard Oil of New York Standard Oil of Ohio Standard Oil Cloth, com. *61 preferred *89i4 __ Standard Paint Co. __ __ __ *105 Standard Roller Bearing, pfd. *12y8 *12y8 Standard Screw, com. preferred A Standard Steel Car Co. Standard Tr. & Sav. Bk. (Chicago) Standard Underground Cable Standard Wall Paper Stanfield's, Limited, pfd. 1 *6.66% basia Stanley Rule & Level , Stanley Works Stark Tusc. Brew., com. preferred *20 Starrett (L. S.) Co., com. State Bank of Chicago State Bank (Hartford) State Bank of Italy (Chicago) State Bank of Kansas City State Bank (New York) State Bank of Maryland (Baltimore) State Bank of Seattle State Bank & Trust (Cleveland) *107 State Bank & Trust (Hartford) State Bank & Trust (San Antonio) State Company of Can. *7%% basis State Exchange Bank (Oklahoma City) State Line & Sullivan Railroad State National Bank (Little Rock) State National Bank (Oklahoma City) State National Bank (St. Louis) State Savings Bank (Charleston) State Savings Bank (Memphis) State Sav. Bank & Trust (Columbus, Ohio) State St. Assoc. (Boston) State St. Ex. (Boston) State St. Trust (Boston) State Trust (Nashville) Steam Boiler Ins. (Hartford) Steel Co. of Canada, com preferred Sterling Bank of Canada Sterling Cork & Seal Sterling Oil & Dev. Sterling Typewriter, pfd. Stem Bros., pfd. 'Quotation nearest March 1, 1913. No quotation on that date. 1072 75 91 95 •300 •400 172 174 •275 •280 •90 ~ 390 398 $55 $56i/a ~ eVa •200 395 398 195 __ 140 145 •160ya 200 250 $32 $36 130 140 195 ~~ 200 — 115 11 •121/, > — 100 110 150 210 135 150 265 275 135 140 $75 $75 __ 275 __ 90 100 $300 __ 25 861/3 881/4 •96 •103 •15 1.05 •97ya 74 78 High Low Bid Asked Stetson (J. B.), com. 420 preferred -. *180 Stevens Manufacturing (Fall River) __ __ __ I26I/2 Stewart Mining 11/2 ll^ Stewart -Warner Speedometer, pfd. __ __ __ *99 Stock Yards Bank (Louisville) __ __ 140 Stock Yards Bank & Trust (Cincinnati) __ __ 145 175 Stockyards National Bank (Fort Worth) __ __ 130 150 Stock Yards National Bank (St. Paul) __ __ 150 Stock Yards National Bank (So. Om.) __ __ 200 250 Stock Yards Savings Bank (Chicago) __ __ 300 Stockmen's Trust, Savings Bank (Chicago) 150 155 Stonega Coke & Coal, com. __ __ *14 *17 Stray Dog Mining (Nevada) __ __ 3c Streets W. Stable Car, com. 8 8 __ __ ^preferred 45 50 Stromberg-Carlson Manufacturing, com 9l^ 12 preferred 50 Studebaker Corporation, com. 29 32 preferred __ • __ 88 93 Stuyvesant Insurance (New York) __ __ 140 155 Submarine Signal 5 7l^ Suburban Realty 10l^ Suffolk R. E. Tr. (Boston) __ __ __ $750 Sulzberger & Sons, pfd. . __ 97 100 Summer St. Tr. (Boston) __ __ __ $92 Sun & Hastings Loan Co. __ __ __ $85 Sun Drug __ __ 0.95 Sun Insurance (New Orleans) % 2^2 Superior & Boston Copper __ __ 3% A% Superior Copper Mining __ __ 28 28^4 Superior Savings & Trust (Cleveland) __ __ 295 Superior Water, Light & Power, com 50 preferred 87 Swan & Finch Co. __ __ __ *210 Swift & Co. 106% 106% Swinehart Tire & Rubber __ __ *93 Symington (T. H.) Co., pfd. __ __ *60 • *72 common *10 Tabasco Plantation Co. __ _•_ *30 Taber Mill (New Bedford) __ __ __ 1071/3 Tacoma Gas, com. 20 preferred 68 Tacony Trust (Philadelphia) *225 *225 Tamarack Mining __ 30 32 Tampa-Cuba Sugar __ __ *15i^ *18 Tampa Electric __ __ 150 155 Taunton Gas Light __ __ _„ fl^S Taunton (Massachusetts) National Bank 107 Taylor & Fenn __ __ 165 Tear-Off Bottle Seal Co. __ __ __ '36 Tecopa Consolidated Mining (Nevada) — 10c 15c Tecumseh Mills (Fall River) __ __ 115 120 Tenderfoot Hill (Colorado Springs) __ __ .0035c Ic Tenn Copper $37% $37 Tenn. Ry., Light & Power, com. __ __ 21 22 preferred — 751/3 761^ Tenth & Twenty-third St. Ferries __ __ 25 35 •Quotation nearest March 1, 1913. No quotation on that date. f'Value" as of March 1, 1913. 1073 High Low Bid Asked Tenth National Bank (Philadelphia) *117l^ *117i4 Term. Hotel Tr. (Boston), pfd. __ __ __ $95 Terre Haute & East. Indiana R. R., pfd __ __ __ *60 common *13V2 Terre Haute National Bank __ __ 150 160 Terre Haute Traction & Light, pfd. __ __ IO314 lOTVs Terry, Trench & Proctor Tun. Mch. __ — __ *4y3 Teutonia Insurance (New Orleans) 122 Teutonia Insurance (Pittsburgh) $103 Teutonia Loan & Building *97 Teutonia National Bank (Dayton) __ 140 Texas & Pacific I81/2 ISy^ Texas & Pacific Coal __ _- 95 100 Texas Bank & Tr. (Beaumont) __ __ 125 Texas Bank & Trust (Galveston) __ __ 215 225 Texas Co. 115 115 Texas Pacific Land Tr. Cert. __ _. $91 $105 Texas Power & Light, pfd. __ __ 97 100 Texas State Bank (Ft. Worth) __ __ 125 Texas Traction, com. __ __ __ 15 preferred __ __ 75 Textile National Bank (Philadelphia) *125y8 *125% — Thames National Bank (Norwich) __ — __ 170 Thanksgiving Mining (Nevada) — — __ Ic Third Avenue Ry. 36 36 Third National Bank (Atlanta) „ __ 240 255 Third National Bank (Buffalo) __ __ 150 160 Third National Bank (Dayton) __ „ __ 200 Third National Bank (Jersey City) „ „ 290 300 Third National Bank (Philadelphia) •250^*25014 __ Third National Bank (St. Louis) __ __ __ 258 Third National Bank (Scranton) __ __ 900 910 Third National Bank (Springfield) ._ __ 225 233 Thirteenth & Fifteenth Sts. Pass. Ry. *$249y2 — Thomas Iron, pfd. — — *24 ^31 Thompson Starrett, com. — __ *161 '167 preferred — — — *112ya Thomdike Co. (Massachusetts) (par $1,000) __ __ 1500 Tippecanoe Securities, pfd. — — *10V2 *11 Title Guarantee & Trust (New York) __ __ 480 490 Title Guaranty Trust (St. Louis) „ __ 72 72% Tobacco Products, com. — 120 140 preferred — — 90 93 Toledo Home Tel. __ — 100 100% Toledo, Peoria & Western __ __ 15^4 __ Toledo Ry. & Light — — — 12y3 Tol. St. L. & W., pfd. 27y8 27 common — — 10 12 Toledo (Ohio) Savings Bank & Trust — — 255 300 Tonopah Belmont Dev. — — 7y8 7*4 Tonopah Extension Mining (Nevada) $1.75 $1.75 Tonopah Gypsy Queen Mining (Nevada) __ __ 3c 4c Tonopah Merger Mining (Nevada) 85c 81c Tonopah Mining of Nevada -$6 $6 Tonopah 76 Consolidated Mining (Nevada)— __ — __ 7c Tooke Brothers, pfd. — — 90 Toronto, Bank of (Canada) — — — 208 Toronto General Trusts ^200 Toronto Mortgage *140 'Quotation nearest March 1, 1913. No quotation on that date. 1074 High Low Bid Asked Toronto Paper __ 78 Toronto Railway __ __ 138 1381/3 Toronto Savings *185 Toronto Structural Steel, pfd. *97y2 *97y2 Torrington Co., com. __ __ $27l^ $28 preferred __ $27 $28 Traders' National Bank (Birmingham) __ __ 160 170 Traders' National Bank (Ft. Worth) __ __ 300 325 Traders' National Bank (Kansas City, Mo.) 160 Traders' National Bank (Rochester) __ 165 180 Traders' National Bank (Scranton) __ 220 225 Traders' National Bank (Spokane) __ __ 190 250 Traders' Oil __ __ 691/2 72 Tradesmen's National Bank (Philadelphia)— *250 *250 Tramp Consolidated Mining (Nevada) __ __ __ Ic Tramps Merger *81 *81 Tramps Mining *li^ *li^ Traute & Hine __ __ $55 $60 Travelers' Insurance (Hartford) __ __ 640 650 Travelers' Life Insurance (Hartford) 630 640 Tremont Bldg. Tr. (Boston) __ __ $102 $107 Tremont & Suffolk Mills (Massachusetts)— *110% __ Trenton Banking Co. *$112 *$112 Trenton Potteries, com. 4 7 preferred 50 65 Trenton Trust & Safe Deposit 278 278 Trethewey Silver Cobalt __ 40c 43c Ti-Bullion Smelting & Develop. ^ 1/2 Trim'tn Tr. (Boston) __ __ $90 Trinidad Electric, pfd. *75 *75 common *$3.60 *$3.60 Trinity Copper __ __ 4% 41/3 Ti-State Tel. & Tel., com. __ __ $10 preferred __ __ $91/2 $10 Trow Directory 'le^A *16l^ Troy & Greenbush __ __ $80 $85 Troy (New York) Gas — __ 210 225 Troy Trust Co. __ __ 170 175 Trust & Guarantee Co. of Toronto __ __ __ *95 Trust Co. of Georgia (Atlanta) 247 251 Trust Co. of New Jersey (Hoboken) __ __ 380 410 Trust Co. of St. L. Co. __ __ __ $198 Tucapan Mills (South Carolina) __ __ 300 350 Tuckett's Tobacco, com. 57 59 Tularosa Mining __ — 1/2 % Tuolumne Copper Mining 21J 2% Turners Falls Power & Electric __ __ __ tl65 Twenty-third Street Railway — __ 240 265 Twenty-third Ward Bank (New York) __ __ 175 Twin City Rapid Transit, com __ __ 105 108 preferred — — 138l^ 145 Uncas National Bank (Norwich) __ __ 100 Underwood Computing Machine — — — *40 Underwood Typewriter, com __ __ 93 97 preferred — — __ 111 113 Union & New Har. Trust (New Hampshire) — 155 Union & Planters' Bank & Trust (Memphis). __ __ 170 172 Union -American Cigar, com *30 •Quotation nearest March 1, 1913, No quotation on that date. fValue" -as of March 1, 1913. 1075 High Low Bid Asked Union Bag & Paper, pfd 341/2 341/2 • common 5% Syg — -- Union Bank (Altoona) . Union Bank of Canada Union Bank of Chicago Union Bank (Richmond) Union-Buffalo Mills (South Carolina) 1st pfd. Union Carbide Union Consolidated Mining (Nevada) 10c 9c Union Construction Co Union Copper Land & Mining Union Cotton Manufacturing (Fall River) Union Dairy (St. Louis) Union Exchange National Bank (New York). Union Ferry (New York and Brooklyn) Union Gas & Electric (Cincinnati), com preferred Union Life Insurance Co Union Manufacturing, New Britain Union Mines Union National Bank (Charlotte) Union National Bank (Cleveland) *165 Union National Bank (Houston) Union National Bank (Louisville) Union National Bank (Newark) Union National Bank (Philadelphia) *213 *213 Union National Bank (Scranton) Union National Bank (Troy) Union National Bank (Wilmington, Dela.) Union Natural Gas Union Oil Union Pacific, com 153% I521/2 preferred 84% 84% Union Passenger Railway (Philadelphia) *$193 Union Provident Co Union Railway, Gas & Electric, com preferred Union Safe Deposit & Trust (Portland, Me.)_ Union Sand & Mat Union Savings Bank (Augusta) Union Savings Bank (Toledo) Union Savings Bank (Washington) Union Savings Bank & Trust (Cincinnati) Union Savings Bank & Trust (Memphis) Union Savings & Loan (Cleveland) *114 Union Savings & Trust (Seattle) Union State Bank (Minneapolis) Union Station Bank (St. Louis) Union Steam Pump Union Stock Yards Bank (Buffalo) Union Stock Yards (South Omaha) Union Sugar Co. Union Switch & Signal, com. preferred Union Tank Line Union Traction (Philadelphia) Union Trust (Albany) Union, Trust (Baltimore) Union Trust (Canada) 'ISO *Quotatlon nearest March 1, 1913. No quotation on that date. 1076 160 175 150 152 170 175 $360 40 185 187 •8 •18 iy4 IVa 210 __ 145 160 170 15 19 5 65 •51/2 $52 Vs y4 162 198 201 245 265 375 ~ 135 140 60 621/2 $83 $90 129 130 92 921/8 loiys 1041/8 61 64 87 901/2 180 200 __ 77 $80 220 245 246 410 500 320 350 135 —-■ 115 __ 140 •50 128 130 951/2 1 96y. 271/2 , 30 $1261/2 $127ya $129 *67 •69 $49% , $501/8 350 $63 $66 High Low Bid Askea Union Trust (Chicago) __ __ 320 Union Trust (Detroit) , __ __ 185 190 Union Trust (Harrisburg) 135 Union Trust (Indianapolis) 313 Union Trust (Jersey City) __ __ 105 115 Union Trust (Lancaster) $148 $150 Union Trust (Little Rock) __ __ 180 Uion Trust (Nashville) __ __ 95 100 Union Trust Co. (New York) __ __ $1290 1300 Union Trust (Providence) >. __ 175 1801/2 Union Trust (Rochester) __ 190 215 Union Trust (Springfield, Mass.) __ __ 230 240 Union Trust (Washington) __ __ 136y8 136^^ Union Trust & Savings Bank (Spokane) 120 135 Union Typewriter, com. __ __ 33l^ 1st preferred 102 105 2nd preferred 97 99 Union Wadding Co. (Rhode Island) ._ __ __ *118 United Bank & Savings (Cleveland) *285 United Box Board __ __ li/s 1% United Cigar Manufacturers, com. 49 53l^ preferred __ __ 981^ 103 United Cigar Stores, com. 101% 101% preferred 114 116 United Copper, com. % % United Dry Goods, com. __ 961/3 98 preferred __ __ 99% 10^^ United Electric Light of Springfield __ __ __ t285 United Electric, New Jersey 90 95 United Electric Securities, pfd. __ 112 United Equities Corp. of Virginia, pfd *97 *97 United 5 «& 10 Cent Stores __ __ *42 *43 United Firemen's Insurance (Philadelphia)— $15 United Fruit __ __ 1701/2 171 United Gas & Electric, pfd. __ __ 85 90 United Gas Improvement __ __ $88% $88% United Gold Mines (Colorado Springs) 5c 5%c United Illuminating (New Haven) __ __ '195 205 United Light & Railways, com. 80 83 1st preferred __ 80 81 2nd preferred 74 77 United Mercantile Co., pfd. __ *7 United National Bank (Providence) 210 United National Bank (Troy) __ __ 295 300 United N. J. R. R. & Canal __ __ 235 238 United Oil __ __ 35 36 United Petroleum __ __ 103% 104% United Public Utilities (Delaware) __ 25 United Railways & Electric (Baltimore), com. $23% $231/2 United Railways Investment, com. __ __ 26% 27% ^preferred 49 52 United Railways of St. Louis, com. __ 13% 13% preferred __ __ 39% 40% United Sec, Loan, Ins. & Tr. (Philadelphia) *140 *140 United Shoe Machinery, com. __ __ $49% $50 preferred __ __ $27% $28 United States & Mexican Trust __ *80 United States Bank (Hartford) __ __ 475 ♦Quotation nearest March 1, 1913. No quotation on that date. fValue" as of March 1, 1913. 1077 High Low United States Bob. & Shut., com. preferred United States Cashier Co. United States Casualty U. S. C. I. P. & F., com. 131/2 131/3 preferred United States Envelope, com. preferred United States Express United States Fidelity & Guar. (M.) United States Finishing, com. preferred United States Gypsum, pfd. United States Hotel (Boston) *nO 'ITO United States Industrial Alcohol, com. preferred United States Insurance (New York) United States Light & Heat, com. preferred U. S. L. D. T. & S. Co., pfd. United States Metal Products, pfd. common United States Motor, com. preferred New 1st preferred 2nd preferred United States Mortgage & Trust (New York) United States National Bank (Los Angeles) United States National Bank (Omaha) United States Operating Co. United States Playing Card United States Printing of Ohio United States Radiator, com. preferred United States Realty & Improvement United States Reduction & Refining, com. preferred United States Rubber, com. 62% 62 1st preferred IO614 106l^ 2nd preferred United States Safe Dep. (New York) U. S. Safe Dep. & Sav. Bank (New Orleans) United States Smelt., Ref. & Min., com preferred United States Steel, com. 6I1/8 6014 preferred 1071/5 IO71/2 United States Telephone (Cleveland), com *32 preferred *79i/^ __ United States Title Guar. & Ind. United States Trust (Louisville) United States Trust Co. (New York) United States Trust (Terre Haute) United States Trust (Washington) United States Worsted, pfd. United Traction (Pittsburgh), pfd. United Traction & Electric, com. preferred 1 'Quotation nearest March 1, 1913. No quotation on that data. 1078 Bid Asked 25 100 105 *100 190 200 54 62 115 125 102 106 50 55 195 200 *15 *20 ♦40 __ ~ •79 35 95 100 $16 8 10 55 65 10 15 •100 •40 ^ % % IVs 10 71 35 460 470 150 300 350 *n% 148 160 761/4 82 *9% •40 50 69 70 1 1% 3 6 71 81 190 235 $39% $39% $48 $48% 87y2 138 140 1100 1115 90 100 137 140 •1001/2 $35 100 1031/, 77i } baiifl High Low Bid Asked United Utilities, com. 37 4u preferred __ __ 100 lOSVa United Wine & Trading , __ __ *40 United Wire & Supply, pfd. __ __ __ lOSy^ United Xpidite Finishing *3i4 United Zinc, com. __ 8c 20c preferred 1% 2Vi Universal Trading & Supply "4 University Assoc. (Cambridge) $100 Upham Bros & Co., pfd. *102i/2 *102y8 Upson Nut, pfd. 108 Utah-Apex Mining 1% 2 Utah Consolidated Copper 9^/4 9^ Utah Copper $548/3 $52% Utah Gas & Coke, com. __ 102l^ Utah Metal Mining 94c $1 Utah Mining (Nevada) 5c 6c Utah Savings & Trust (Salt Lake City) __ __ 102 103 Utah Securities __ 23 23ya Utah St. National Bank (Salt Lake City) __ __ 295 301 Utica & Black River, gtd. __ __ *1Q9 Utica & Willowvale Bleachery __ __ 200 Utica, Chen. & Susq. Vy. __ __ 141 146 Utica City National Bank __ $25.85 $26Vi Utica, Clinton & Binghamton __ 65 75 Utica Knitting, pfd. __ 100 103 Utica Steam & Mohawk Valley Cott. M __ __ 165 167 Utica Trust & Deposit Co __ __ 400 Utilities Improvement, com. __ __ 69 75 preferred __ __ 75l^ 76% Vacuum Oil Co. __ __ *175 *180 Valley Railroad (New York) __ __ 115 125 Valley Steamship *85 Van Camp Hardware & Iron, pfd •lOO Vanadium Sales Co. of America '325 Vandalia Coal, com. 5 preferred 7 15 Vandalia Railroad 85^4 Vandeveriter Trust (St. Louis) . 100 110 Vermont & Massachusetts Railway 150 Vernal Mining (Nevada) ^ 12c 13c Veronal "U *14 Victor Talking Machine, com. *310 Victoria Copper Mining __ __ 1^ ly^ Virginia Building & Loan __ 110 Virginia-Car. Chemical, com. 32% 32% preferred 108% 108% Virginia Fire & Mar. Insurance (Richmond) __ __ $81 $83 Virginia Iron, Coal & Coke — __ 51 54 Virginia National Bank (Norfolk) __ 140 150 Virginia National Bank (Petersburg) __ 135 Virginia Railway and Power, com. 51% 50% preferred — 89 Virginia State Insurance, com. __ __ $10 Va $lll^ preferred — __ $16 $17 Virginia Trust Co. (Richmond) _ __ __ 158 160y, Virginian Railway — 15 20 Vulcan Detinning, com. — __ 16% 20 preferred — — 35 ♦Quotation nearest March 1, 1913. No quotation on that dat«. 1079 High Low Bid Asked Vulcan Tube Cleaning *47ya *47i/8 Vulcanite Portland Cement __ __ "TS Wabash, com. 4 314 preferred 11 IQV2 Wagner Electric Co. __ __ __ *134 Walker Bros. (Salt Lake City) __ __ 225 230 Walpole Rubber, pfd. •100 'lOO Waltham Watch, com. __ __ 25 28 preferred __ -_ 100 104 Wampanoag Mills (Fall River) — 90 Wamsutta Mills (New Bedford) __ __ 119 123 Ward Baking Co., pfd. .- -_ *93 *95 Ward (Montgomery), pfd. __ _> __ lOiy^ 107% Ware River Railroad _- -_ 174 176 Warner (Charles) Manufacturing, pfd. __ __ *100 common — — — $25 Warren Mfg. (South Carolina), com. 70 80 preferred — __ 100 Warren Railroad (New Jersey) __ __ $811/2 $83Va Warwick Iron & Steel __ — $101/2 $10% Washburn Wire, com. — — __ *115 preferred — — *QVs% basis Washington, Baltimore & Annapolis El., com. $14 preferred $35 Washington (D. C.) Gas Light ._ __ $851/3 $851/2 Washington Heights Bank (New York) 275 Washington Hotel Realty, 1st pfd. __ __ *29 ♦32 Washington Loan & Trust __ „ 238 250 Washington Market __ __ $17% __ Washington Mills (Virginia), pfd. __ __ 106 110 Washington National Bank __ — 244 256 Washington Oil ~ — $31 $35 Washington Park National Bank (Chicago) __ __ 200 Washington Railway & Electric, com. __ __ 84% 85 preferred — — 87% 88% Washington Trust (New York) „ __ 375 395 Washington Trust (Pittsburgh) __ __ 160 Washington Trust (Spokane) — __ 120 130 Washington -Virginia Railway, com. '51 preferred *80 Washington Water Power __ __ 130 133 Waterbury National Bank __ __ $80 $85 Waterbury Trust Co. — „ 100 Waters-Pierce Oil — — *1400 *1550 Wayne Co. Savings Bank (Detroit) __ __ 335 351 Wayne Jet. Tr. (Philadelphia) "110 "110 Webb Mfg. (Nashville, Tenn.) __ __ 70 90 Webster & Atlas National Bank (Boston) ___ __ __ 185 190 Webster & Southbridge Gas & Electric __ __ __ tl45 Webster Citizens Ice — — __ '100 Weetamoe Mills (Fall River) — _- __ 90 Wellington Mines — — — *6i/2 Wellman-Seav.-Morg., com. 31 preferred *10Q Wells-Fargo Express — — 105 112 Wells-Fargo Nev. Nat. Bank (San Francisco) __ __ 170 Welsbach Co., com. — — — 40 West Coast Oil, pfd. — — 70 •Quotation nearest March 1, 1913. No quotation on that date. fValue" as of March 1, 1913. lOSO High Low West End Bank (Richmond) West End Bank & Trust (Cincinnati) West End Consolidated Mining (Nevada) $1.35 $1,321/2 West End Land Co. — — *12 West End Mining *135 *130 West End Sav. Bank & Trust (Pittsburgh) __ *$153 *$153 West End Street Railway, com. preferred West End Trust (Philadelphia) *$118 *$118 West Englewood-Ashl'd St. Bk. (Chicago) West Point Manufacturing West India Electric *7 West Jersey & Seashore, com. $52 $51 West Jersey Trust (Camden) 185 185 West Penn Railways, pfd. West Penn Traction, pfd. common *80 *80 West Penn Tr. & Water Power, pfd. common West Philadelphia Passenger Railway *$205 West Philadelphia Title & Trust *$133 *$133 West St. Louis Trust West Side Bank (Milwaukee) West Side Bank (New York) West Side Bank (Scranton) West Side Dime Sav. Bank, (Columbus, Ohio) West Side Trust (Newark) West Side Trust & Savings Bank (Chicago) West Virginia Traction & Electric, pfd West Point Manufacturing Westchester & Bronx T. & M., guar Westchester Insurance (New York)^ Westchester Trust (Yonkers) Western Canada Flour Mills *12 Western Cities Gas & Electric, pfd *90 *90 Western Exchange Bank (Kansas City, Mo.) Western German Bank (Cincinnati) Western Insurance (Pittsburgh) $60 $50*4 Western Maryland Railway, com. -preferred Western National Bank (Baltimore) Western National Bank (Ft. Worth) Western National Bank (Oklahoma City) — . Western National Bank (York) Western Ohio Railway, com. *23 1st preferred 107 2nd preferred Western Pacific Western Power, com. preferred Western R. E. Tr. Western Silo Co., pfd. Western States Gas & Electric, com. • preferred Western States Portland Cement, com. preferred — Western Stone — Western Union Oil Western Union Teleg. 69 69 •Quotation nearest March 1, 1913. No quotation on that date. 1081 Bid Asked 43 45 142 146 $771/2 78 $95 97 148 150 *104 ~ •79 *80 *80 *85i/2 79 80 32 331/2 120 125 250 300 535 $180 $185 120 270 __ 275 100 *104 __ 165 $571/2 $621/2 150 160 400 — 375 400 401/3 44 60 641/2 $3914 $40 135 150 165 __ — 100 70 75 7 8I/2 20 22 48 50 $135 __ H •100 48 55 90 95 10 50 11% 13 81 100 High Low Bid Asked Westinghouse Air Brake __ __ $138 $143 Westinghouse Auto Air & St. Coupler __ __ __ 3 Westinghouse Electric & Manufacturing, com. $34V2 $35 lat preferred __ _. $571/2 $59y8 Westinghouse Machine *$25 *$27 Westminster Bank (Providence) __ __ $63 Westmoreland Coal $79 Westport Avenue Bank (Kansas City, Mo.) 250 Wettlaufer Silver Mines 14c 13c Weyman-Bruton, com. _> 270 300 • preferred 105 125 Weymouth Light & Power t210 Weymouth Water Power tllO Wheeling & Lake Erie, com. CVg ^Va 1st preferred 19 24 2nd preferred lOi/g lOVa Wheeling Mould & F. __ __ $57 $59 Wheeling Steel & Iron __ __ 147 148 White Co., pfd. __ __ IO71/2 — Wliite (J. G.) & Co., pfd. __ __ *78 •83 common *67 White Star Line __ — __ 501/2 White Star Oil — __ __ 19 Whitman Mills (New Bedford) __ — __ 155 Whitney Central Nat'l Bank (New Orleans) '315 Whitney Manufacturing (South Carolina) 110 120 Wichita Union Stock Yards __ __ __ *76 Wilkesbarre Dep. & Savings Bank __ __ $204 $210 Williamsburg City Insurance (Brooklyn) __ 225 250 Williamson Trust (Memphis) __ __ 100 105 Willys-Overland Co., com. 64 64 preferred __ __ 93 98 Wilmington Gas Co., pfd. __ __ *80 *85 common — — — *^^V2 Wilmington (North Carolina) Sar. & Trust __ __ $175 Wilmington Trust Co. __ __ $120 $130 Wilson & Co. — See Sulzberger & Sons. Winchester Repeating Arms — 1,100 Winnipeg Electric — 214 Winnipeg Paint & Glass, Limited __ „ *7i4% basis Winona Copper __ 21/, 3 Winters National Bank (Dayton) __ __ 165 175 Winthrop Bldg. Tr. (Boston) __ __ __ $65 Winthrop National Bank (Boston) __ __ 325 Wireless Liquidating Co. __ __ __ *1% Wisconsin Central Railway 48 51 Wisconsin National Bank (Milwaukee) __ — 205 Wisconsin Sugar, pfd. *100 "100 Wisconsin Trust (Milwaukee) __ — 160 Woburn Gas Light ._ __ — t200 Wollaston Land — _- % ll^ Wolverine Copper Mining ^ __ __ 67 67i/a Wolverine Oil — — 50c Wolverine Portland Cement Co „ - „ 2i/, 3 Woman's Hotel — __ 70 75 Woodland Savings & Trust (Cleveland) •2101/3 „ Woodlawn Cemetery __ __ '130 Woodlawn Trust & Savings Bank (Chicago) „ __ 200 203 'Quotation nearest March 1, 1913. No quotation on that date. t"Value" as of March 1, 1913. 1082 High Low Bid Asked Woodside Cotton Mills, com. — — 35 40 preferred guaranteed — — 95 100 preferred — _ — — — 93 Woolworth (F. W.), com 96ya 96 preferred — — 113 113 Worcester Electric Light — — — t300 Worcester Gas Light — — — 1'310 Worcester, Nashua & Rochester — — 149 Worcester (Massachusetts) National Bank— — — 225 Worcester Suburban Electric — — — tl65 Worcester (Massachusetts) Trust — — 225 Work (Colorado Springs) — — — .01c Worthington (H. R.), pfd. — _. IO41/2 106 Worthington Pump Co., limited pfd — — *90ya — Wright Wire Co., pfd. 'llO "110 Wrightsville & Tennille, com. — __ $24 $26 Wurlitzer (R.), pfd. — __ 1031/3 „ Wyandot Copper — — % 1 Wyoming National Bank (Wilkesbarre) __ __ $325 $335 Wyoming Valley Tr. (Wilkesbarre) __ — $155 $160 Yale & Towne Manufacturing __ *45 Yale National Bank (New Haven) 140 Yellow Jacket Gold & Silver Min'g (Nevada) __ __ 21c Yellow Taxicab, com __ 10 15 preferred 40 50 Yellow Tiger Consolidated Mining (Nevada) 2c 3c York County National Bank (York) __ __ $541^ $55 York Manufacturing (Maine) *135 York National Bank __ __ $44 $45 York Railways, com. __ __ 12 12% preferred __ __ 35% 36^4 York (Pennsylvania) Trust Co. __ $60 $65 Yorkville Bank (New York) __ __ 690 610 Young (J. S.) Co. __ __ 170 180 Youngstown & Ohio River, com. __ __ TVa preferred *60l^ Youngstown Sheet & Tube, com. *260 preferred *113 Yukon Gold Mines — __ 3 3^8 Zions Saving Bank & Trust (Salt Lake City) __ __ 420 425 *Quotation nearest March 1, 1913. No quotation on that date. fValue" as of March 1, 1913. 1083 BONDS High Low Aberdeen Light & Power 1st 6s, 1931 Acker, Merrall & Condit Deb. 6s, 1923 Acquackanock Water 5s, 1958 Adams Express Coll. 48, 1947 Adams Express Deb. 4s, 1948 Adirondack Electric Power 1st 5s, 1962 Adirondack Railway 1st 41/28, 1942 Advertising Bldg. (Chicago) 1st 51/28, 1914-22- Agricultural Credit Coll. 5s, 1913 5s, 1914 5s, 1915 Akron & Barberton Belt 4s, 1942-. Akron, Bedford & Cleveland 5s, 1915 2d Con. 5s, 1921 Alabama Central 1st 6s, 1918 Alabama Cons. Coal & Iron 5s, 1933 Alabama Great Southern 1st 5s, 1927 ^general 5s, 1927 equipment 4ygS, 1916 Alabama Midland Railway 1st 5s, 1928 Alabama, N. Orl., T. & Pac. Jc. Deb. A 58, 1940 B 5s, 1940 C 5s, 1940 Alabama & New Orleans Transp. 1st 6s, 1932_ Alabama Steel & Shipbuilding 6s, 1930 Alabama, Tennessee & Northern 5s, 1956 Alabama & Vicksburg Con. 5s, 1921 Alaculsey Lumber Ist 6s, 1912-21 Alamagordo & Sacramento Mtn. Ry., 5s, 1928 Alameda Art. Water 5s Albany Railway Cons. 5s, 1930 ^general 5s, 1947 Albany Southern 1st 5s, 1939 Albany & Susquehanna 31/2S, 1946 Albaugh Dover Co. 6s Albia Interurban Ry. 6s, 1914-30 Alden Mills 68, 1932 Alexandria Co. Lighting 1st 5s, 1931 Algonia Central Terminal 1st 5s Algoma Steel Ist Ref. 5s, 1962 Allegheny, Bell. & Perrysville Ist 5s, 1935 Allegheny Valley, Gen. 4s, 1942 Allegheny & Western 1st 4s, 1998 AUentown Gas 5s, 1924 Allentown & Kutztown Traction 5s, 1932 *77ya *77y2 AUentown & Reading Trac. Cons. 5s, 1937 Allentown Terminal 4s, 1919 Alliance Gas & Electric Ist 5s, 1929 I_ " Alliance Gas & Power 1st & Ref. 5s, 1932 'Quotation nearest March 1, 1913. No quotation on that date. 1084 Bid Asked •1011/2 •80 •81 79y I 8II/2 80 81 96 98ya 101 •100 •99 4/5 • 98.72 ♦97.43 90 100 103 95 __ 105 __ •731/5 , __ 102 __ 102 104 5% 4% •105 •107 104 106 101 103 92 94 . ♦100 104 108 90 97 96 100 •100 __ ♦80 98 1031/2 105 1031/2 105 94 98 881/8 ♦77 •100 103 105 •901/2 __ •95 ♦93 — •991/4 991/4 993/4 95% — •1031/2 •72y2 97y2 100 100 1001/2 97 High Low Bid Asked Allis-Chalmers 1st 5s, 1936 — 65% Cent. Tr. Ctfs. of Dep — — 55 eiVg Stamped — — ~ SOVa Alton, Granite & St. Louis 1st 5s, 1944 — — 89 90 Alton Railway, Gas & Electric 5s, 1939 — — *96 Alton Railway & Illuminating 1st 5s, 1915 — — — *100 Altoona & Logan Val. Elec. Con. 41/2, 1933 — — 89 90 Altoona Gas 1st 5s, 1933 — — 98 100 Amalgamated Copper 5% Notes, 1913 — — — *100 Amalgamated Corp. 5% Notes, 1913 — — 99% lOOi/g Amarillo Gas 1st 6s, 1915 — — — *100 American Agr. Chem. Co. 1st Con. 5s, 1928 IOO1/2 lOOVg American Bank Note 5% Notes, 1916 — — — *99i4 American Brake Shoe and Foundry 58, 1952— — — *102i4 — American Can Deb. 5 s, 1928 — — — *97i4 American Cement Serial 6s — — — *100 American Cities 5s, 63, 1919 — — 921/2 931/2 American Cotton Oil Deb. 41/2S, 1915 .— — — 96I/2 97 Debenture 5s, 1931 — — 931/2 93% American District Telegraph 5s, 1926 — — *93 American Dock & Imp. Co. 1st 5s, 1921 — — 1031A IO51/2 American Gas Conv. 6s, 1914 — — 100 101 ^Non-Convertible 5s, 1920 — — 95% 961/3 American Gas & Electric Col. 5s, 2007 — — 86 861/2 American Graphophone 6s, 1930 — *88 American Hide & Leather 6s, 1919 — — IOI1/2 102 American Hominy 5s, 1927 — — -> *100 American Ice R. E. & Gen. 6s, 1942 — __ 98I/3 991/2 American Ice Sec. Deb. 63, 1925 741/2 741/3 American La France Fire Eng. 1st 6s, 1924 — — — 85 American Lithographic 1st 5s, 1921 — *90 American Locomotive 5% Notes, 1914 __ — 1001/4 American Locomotive 6% Notes, 1915-17 — — 5.35-15% basis American Malting 6s, 1914 __ __ 101 102 American Petroleum 6s, 1920 >_ __ 871/3 95 American Pipe & Construction 5s, 1927 — — *99 *100% Secur. 6s, 1922 ._ __ *99 American Pipe & Foundry 6s, 1928 __ __ 100 IO21/2 American Pipe Manufacturing "A" 5s, 1927— __ — *99 American Pneumatic Service Coll. 5s, 1928 — *90 American Power & Light 6% Notes, 1921 __ __ 991/2 99% American Pub. Serv. 1st 6s, 1943 __ __ — 100 American Pub. Util. Coll. 58, 1942 — „ — 921/2 American Railways Conv. 5s, 1931 93 96 Collateral Trust 5s, 1917 __ — 96 American Railways (Johnstown) 5s, 1930 — — — *95 ('Scranton) 5s, 1935 __ — *93 *95 American Real Estate 6s __ __ *95 American Refrigerator Trans. Equip. 5s, 1921_ *100 5s, 1922 __ __ __ *100 American Road Mach. 6s, 1938 __ __ __ *100 American Rolling Mill 6% Notes, 1914-15 — — — "lOO American Sales Book Ist 6s, 1927 — — — *100 American School Furniture 6s, 1939 __ __ — *85 American Sewer Pipe 1st 6s, 1920 — — 87 90 American Smelters Securities 6s, 1926 __ „ 104l^ 105 American Spirits Manufacturing 1st 6s, 1915_ — — __ 99i/^ American S. S. of West Virginia 1st 5s, 1920— — __ *100% — ^Quotation nearest March 1, 1913. No quotation on tbat date. 1085 High Low Bid Asked American Steel Foundries 6s, 1935 __ __ 991/2 101 Debenture 4s, 1933 — — 711/4 731/2 American Tel. & Tel. Coll. 4s, 1929 — — 871/2 871/3 Convertible 4s, 1936 — — IO21/2 103% Convertible 41/2S, 1933 _. — 103 103 American Thread 1st 4s, 1919 — — 93 94 American Timber 6s — — — *95 American Tobacco 6s, 1944 — __ 120 I2I1/2 American Tobacco 4s, 1951 97 97 American Trust Bldg. (Chic.) Ref. 5s, 1914-41 __ __ __ *100 American Type Founderi, Deb. 6s, 1939 __ __ 991/2 101 American Writing Paper 1st 5s, 1919 __ __ 891/3 891/2 Americus Gas & Electric 5s, 1942 25 25 Ames Plow Ist 53, 1932 — — __ *101 Anacostia & Potomac 5s, 1949 — — 98 Anacostia & Potomac (Guaranteed) 5s, 1949— __ __ 103 IO414 Annapolis Gas & Electric 1st 6s, 1921 __ __ •105 Annapoli* Gas & Electric Cons. 53, 1953 __ __ __ *95 Ann Arbor Railway. — 5% Notes, 1913 — __ — *98 Equipment 5s, 1919 __ — *100 "B" 5s, 1913-21 -_ — — 'lOO Ist 4s, 1995 __ — 75 76 Annuity Realty (St. L.) S. F. Part. Ctfs., 1952 — __ __ *97i/2 Annville & Palmyra Gas & Fuel 1st 5s, 1930 __ __ __ *95 Appalachian Power 5% Notes, 1914 *99 Appalachian Power 6% Notes, 1914 __ *6i/2% basis Appalachian Power 1st 5s, 1941 __ __ 77 78 Ardmore Street Railway 5s, 1958 __ __ 96 98 Arizona Power 1st 6s, 1933 __ __ 80 86 Arkansas Natural Gas 6s, 1922 __ __ __ *96 Arkansas, Oklahoma & Western 1st 63, 1947— — — 93 100 Arkansas Water 6s, 1914 __ __ *99% __ Armour & Co. Ist 41/38, 1939 __ ._ 90% 91 Aroostook Construction 5% Notes, 1917 — — — *96% Aroostook Northern 1st 58, 1941 __ __ __ 'lOli/g Aroostook Valley Electric 41/2S, 1929 >_ — '97 *100 Arundel Sand & Gravel 6s, 1923 __ __ — 98i^ Ashdown Hardware 5s, 1928 __ __ __ *90.20 Asheville Power & Light 1st 5s, 1943 __ — 93 96 Asheville & Spartansburg 1st 4s, 1995 „ __ 80 85 Ashland Light, Power & St. Ry. 1st 5s, 1939_ — — 95 99 Ashland Water 6s, 1929 __ „ — *100i/2 Associated Gas & Electric 5s, 1939 — — "95 Associated Oil 5s, 1922 __ __ __ 102 Associated 'Simmons Hardware Coll. 5s, 1917- — — 514% basis Astoria (N. Y.) Veneer Mills & D. 1st 6s, 1941 — — 100 105 Atchison & Eastern Bridge 5s, 1928 __ — 82 85 Atchison Railway, Light & Power 1st 5s, 1935 __ — 90 961/2 Atchison, Topeka & Santa Fe Railway. — California & Arizona "B" 41/oS, 1962 — __ 100 IOO1/2 S. F. Pres. & Ph. 5s, 1942 __ _. *106% ._ (East Oklahoma Division) 1st 4s, 1928— _^ — — 95% 5s, 1917 _. __ 101% 102 Deb. 4s, "L," 1914 __ __ 991/2 — Convertible 4s, 1955 ._ __ 10114 102 Convertible 4s, 1960 10014 lOOVg Trans. Sh. Line 1st 4s, 1958 „ — __ 90i4 ^Quotation nearest March 1, 1913. No quotation on that date. 1086 High Low Bid Asked General 4s, 1995 (Coupon) — — 96% 97 General 4s, 1995 (Regular) — — 96 971/2 Adj. 4s, 1995 (Coupon) — — — 88 Adj. 4s, 1995 (Regular) — — — 871/3 Adj. 4s, 1995 (Stpd.) — ~ 87 88 Adj. 4s, 1995 (Reg. & Stpd.) — — — 871/3 A^thens Rv. & Electric 1st 5s, 1950 — — 85 90 Athens Terminal 5s, 1937 — — *91 Athol & Orange Street Railway 1st 5s, 1915— — — — 100 Atlanta, Birmingham & Atlantic Railway. — 1st 5s, 1936 — — 25 Equip. 5« due to 1917 — — — 100 5% Rec. Ctfs., 1913 — — — *100 Atlanta Cons. St. Ry. 5«, 1939 — — 1041^ 104% Atlanta Gas Lt. 1st 5», 1947 — — 102 Atl., Knoxville & Nor. Ist Ss, 1946 __ — 107 Atl., Knoxville & Nor. Cons. 48, 2002 — — — 93 Atlanta Northern Ry. 1st 5s, 1954 __ — 99 IO21/3 Atlanta Steel Serial 6s, 1911-30 — — — *100 Atlanta, Tennessee & Ohio 1st 6s, 1913 __ __ 100 Mlanta Water & Elec. Power 1st 5s, 1943 — __ *89 Atlantic Ave. Con. 53, 1931 — — 102 104 Atlantic Avenue Imp. 5s, 1934 __ __ *100% __ Atlantic & Birmingham 1st 4s, 1933 — __ 84 Atlantic & Birmingham l«t 58, 1934 __ __ 99 101 Atlantic City Elec. Ist & Ref. 5s, 1938 __ — 97 99 Atlantic City Gas 1st 58, 1960 __ __ 86I/3 871/3 A^tlantic City R. R. 53, 1919 __ __ IO21/3 IO31/3 Atlantic City R. R. 1st Cons. 4s, 1951 __ __ 93 94 Atlantic Coast Elec. 1st 5s, 1945 __ __ 96 Atlantic Coast of Conn. Irr. 5s 103 Atlantic Coast of Conn. Irr. 4s, 1925 __ 901/3 Atlantic Coast Line of S. C. Gen'l 4s, 1948 __ __ 941/3 95 Atlantic Coast Line R. R. — Conv. Deb. 43, 1939 __ _. 97 971/3 Unif. 4s, 1959 __ __ 88I/3 891/3 Equip. 4s, 1917 __ __ __ *98% Equip. 41/2S, 1921 __ __ __ *99i/3 1st 4s, 1952 __ __ 93 94 Coll. 4s, 1952 90% 90% Ala. Mid. 5s, 1928 __ __ 105l^ __ Charl. & Sar. 7s, 1936 __ __ 128 L. & N. Col. 4s, 1952 __ __ 901/3 90% Sav., Fla. & W. 6s, 1934 ._ __ 118% I2314 Sav., Fla. & W. 5s, 1934 __ __ IO61/2 II21/3 Atlantic & Danville 1st 4s, 1948 __ __ 88l^ — Atlantic & Danville 2d 4s, 1948 __ __ 83 Atlantic, Gulf & W. I. S. S. Lines 5s, 1959 __ __ 60 62 Atlantic & Yadkin 1st 4s, 1949 __ __ 83% __ Atlas Portland Cement 1st 6s, 1925 __ >_ 101 IO31/2 Atlas Powder Inc. 6s, 1923 __ __ *97i/3 *99% Auburn & 'Syracuse 1st 5s, 1942 __ 98 100 Auburn Gas 1st 5s, 1927 __ __ *94 Auburn Gas Cons. 5s, 1930 __ *98 Augusta- Aiken Ry. & E. Corp. 5s, 1935 __ __ 90 94 Augusta Factory 1st 6s, 1915 __ __ 99 100 Augusta Ry. & Electric 5s, 1940 __ __ 101 103 Augusta Southern 5s, 1924 __ __ 90 95 •Quotation nearest March 1, 1913. No quotation on that date. 1087 Bid Asked 112 117 931/4 " 100 105% *100 __ 95 80 84 *63 •993/4 *96 ~ •943/4 100 loovg •100 103% 104 74 76ya 100 100V2 106 97 104 __ High Low Augusta Terminal Ist 6s, 1947 Aurora, Elgin & Chicago 1st 58, 1941 *100% __ Aurora, Elgin & Chicago 1st 5s, 1946 Austin & Northwestern 1st 5s, 1941 Austin Gas Light Ref. 6s, 1931 Austin St. Ry. 1st 53, 1936 Automatic Elec. Ist 6s, 1938 Autosales Gum & Chocolate 68, 1931 Ayer Mills 41/oS, 1913-15 Ayer Mills 41/2% Notes, 1916 Ayer Mills 41/3% Notes, 1917 Baden & St. Louis 1st 5s, 1913 Bagdad Land & Lumber 1st 6s, 1915 Baldwin Loco. Wks. 5s, 1940 Baltimore & Ann. Short L. 5s, 1946 Bait. Catonsv. & Ellicott Mills Pass. 5s, 1916 Baltimore, Chesapeake & Atlantic 1st 5s, 1934 Baltimore Co. Water & Electric 5s, 1946 Baltimore & Cumberland Valley 1st 6s, 1929_ Baltimore & Cumberland Valley Ex. 6s, 1931_ Baltimore Electric 1st 5s, 1947 99l^ 9914 Baltimore & Harrisburg 5s, 1936 __ __ __ 105 Baltimore & Harrisburg 1st 5s, 1938 __ 100 Baltimore & Ohio R. R.— 41/2 Notes, June, 1913 Equip. 41/2, 1933 (Pitts. June.) 1st 6s, 1933 (Southwestern) 31/38, 1925 Conv. 41/2S, 1933 95^^ 951/2 Prior Lien 31/2S, 1935 (Coup.) Prior Lien 31/2 s, 1935 (Reg.) Pitts., L. E. & W. Va. 4s, 1941 Monon. River 5s, 1919 Gen'l 4s, 1948 96 96 Gen'l 4s, 1948 (Reg.) Pitts. Jc. & Mid. 31/3S, 1935 Baltimore, Sparrows lPt& Ches. 1st 41/3S, 1953 Baltimore Trac. 5s, 1939 Baltimore Trac. (No. Bait. Div.) 1st 5s, 1943. Bangor & Aroostook R. R. — 1st 5s, 1943 Cons. 4s, 1951 Piscat. Division 5s, 1943 St. John's River Ext. 53, 1939 Van Bur. Ex. 5s, 1943 Wachburn Ex. 5s, 1939 Car Tr. "C" 5s, 1906-16 Bangor Power A & B Bonds, 1931 Bangor Ry. & Elec. 1st Cons. 5s, 1935 Barber Asphalt Paving Deb. 6s, 1916 Barney & Smith 5s, 1936 Barrett Mfg. 6s, 1939 Battle Creek & Sturgis 1st 38, 1989 Bay City & Battle Creek 1st 3s, 1989 Bay City Gas 1st 5s, 1930 Bay Counties Power Co. 5s, 1930 Bay of Quinte Ry. 1st 5s, 1927 •Quotation nearest March 1, 1913. No quotation on that date. 1088 99% 100 45/8% 4%% 88 891/4 901/4 90% 91 881/3 881/4 893/4 ^1031/3 .. 97% 88 95 95% 105 107 108 105 108 78 80 99 101 93 97 100 104 93 95 « 100 931/4 99 98% 101 •97% 90 •90 72 67 •90 101 10134 — 96% High Low Bay State St. Ry. 5% Notes, 1913-32 Beaver River Power 1st 6s, 1914-28 Beaver Valley Trac. Gen. 5s, 1953 — ^— Beaver Valley Water 1st 53, 1932 Beech Creek Coal & Coke 58, 1944 Beech Creek Ext'n 1st 31/28, 1951 Beech Creek R. R. Extd. 4s, 1936 Beech Creek R. R. 2d 5s, 1936 Bel. Air Elec. 1st 6s, 1940 Beld-Paul-Cortic. Silk, Deb. 5s, 1936 Belleville & Carondelet 1st 6s, 1923 Belleville Gas & Electric 1st 5s, 1922 Bellingham Bay & Brit. Col. 1st 5s, 1932 Bells Gap Cons. 6s, 1913 Bell Tel. of Can. Deb. 5s, 1925 Beloit Water, Gas & Elec. 5s, 1937 Belt R. R. & Stk. Yards 1st 43, 1939 Belt Ry. of Chattanooga 1st 5s, 1945 Belt Ry. of Chattanooga 2d 43, 1945 Belvidere Delaware R. R. Cons. 31/33, 1943 Belvidere Delaware R. R. Cons. 4s, 1927 Bennington & Rutl. 41/2S, 1927 Benton Harbor, St. Jos. Gas & Fuel 5s, 1926— Bergen Turnpike Ist 53, 1951 Bergner & Engel Brew. 63, 1921 Berkshire St. Ry. 1st 5s, 1922 Berlin Mills 5s, 1931 Bethlehem Steel 5s, 1926 951/3 951/2 Bethlehem Steel 1st Ref. 53, 1942 Bethlehem Steel P. M. 6s, 1998 Big Lost River Irr. 1st 6s, 1915-23 Big Sandy Ry. 1st 4s, 1944 Binghamton Gas Wks. 1st 5s, 1938 Binghamton Lt. Ht. & Pr. 1st 5s, 1942 Binghamton Ry. 5s, 1931 Birmingham Belt 1st 4s, 1922 Birmingham, Ensley & Bess. Ist 5s, 1941 Birmingham, Knox. & Allent'n 6s, 1931 Birmingham Ry. & Elec. 1st 5s, 1924 Birmingham Ry., Lt. & P. Gen. Ref. 41/38, 1954 Birmingham Ry. Lt. & Pr. 6s, 1957 Birmingham & Southeastern 1st 63, 1961 Birmingham Terminal 1st 4s, 1957 1 Bitter Root Valley Irrig. 1st 6s, 1914-19 Blackstone Val. Gas & Elec. Ss, 1939 Blackwell Lumber 1st 6s, 1912-21 Blazier Timber 1st & Gen. 6s, 1912-17 Bleecker St. & Fulton Ferry 1st 48, 1950 Bliss (E. W.) Co. 6s, 1932 Bloomfield St. Ry. 1st 5s, 1923 Bloomingham & Normal Ry. & Lt. 1st Ss, 1928 Blooming. Decat. & Champ. 1st & Ref. 5s, 1940 Bloomington & Nor. Ry. El. & Ht. 1st 5s, 1927 Bloomington, Pontiac & .Joliet EL 1st 5s, 1935 Blue Creek Coal & Land 1st 5s, 1938 ^_- Blue Ridge Electric 1st 5s, 1940 Blue Ridge Power Gtd. 5s *6% basi» Bluflf Point Land Imp. 1st 4s, 1940 __ __ 85 90 'Quotation nearest March 1, 1913. No quotation on that date. 1089 Bid Asked 100 *6% basis *93 *96 *90 ■ ♦911/3 84 98 106 *90 __ •89 IO8I/3 *94 99 100 100 1001/3 *92 98 100 *70 87 97 __ 95 __ ♦93 ♦94 100 *101 ♦103 ~ ♦100% 85 86 117 117y2 ♦30 851/8 873/4 98 100 97 100 *96 ♦97% 90 __ ♦70 106l^ 107% 104 105 89 91 102 98 101 85 88 ♦100 99 101 ♦100 ♦991/2 68 76 '1021/2 •99 ♦97 •911/3 __ *96 __ ♦321/3 ♦50 __ ♦75 'Q% basis High Low Bid Asked Boca & Loyalton 6s, 1923 — __ 105 Boise City Gas Lt. & Coke Ss, 1941 __ ._ *90 Boise-Payette River Elec. Pow. 6s, 1921 __ __ *95 Bon Air Coal 2d 6s, 1928 — — 90 100 Boomer Coal & Coke Equip. 5s, 1915-17 — — *98% __ Boone Elec. 1st 6s, 1931 — „ — *100 Boonville R. R. Bridge 1st 4s, 1951 __ __ 80 Boonville, St. L. & Son. 5s, 1951 — „ — 101 Booth Fisheries Deb. 6s, 1926 __ __ __ 96 Booth Mfg. 1st Conv. 4y2», 1931. „ __ __ *100 Bonner Coal & Coke 5s, 1912-17 — __ *98% _. Boston & Albany R. R. — 41/81, 1937 — -_ — 103 48, October, 1913 __ __ 99l^ 99% 4s, 1933 __ __ 94 96 4s, 1934__J __ __ 94 96 4«, 1935 >_ __ ' 94 96 31/38, 1951 __ _- 83 85 Ref. 3i/a8, 1952 — __ 83 85 Equip. 41/aS, 1913-27 __ __ __ *100 Boston Elec. Light 1st 5s, 1924 — __ "107 Boston Elevated Deb. 4s, 1937 — — 94 Boston Elevated Deb. 41/2S, 1941 __ „ 931/2 — Boston Elevated 53, 1942 __ — 101 Boston Elevated Ry. 4s, 1935 __ — 88 91 Boston & Lowell R. R. — 41/2S, 1933 __ __ 1011/2 1025/8 4s, 1915 __ „ 98I/2 991/3 4s, 1916 __ _- 98 99 Oct. 1st 4s, 1918 — -_ 97 9314 31/28, 1919 __ __ 94 951/3 31/28, 1921 __ -_ _- 94% 4a, 1932 _- __ 94 961/9 Boston & Maine R. R. — 41/2S, 1929 __ __ 97 991/3 4s, 1926 __ __ 921/2 94l^ 31/aS, 1921 __ _. 901/2 92 31/2S, 1923 __ __ 90 91 3s, 1950 __ ._ 69 72% 6s, 1914 __ __ *99y8 __ 41/2S, 1944 __ __ 97 991/2 48, 1937 ._ __ 90 913/8 4s, 1942 __ __ 891A 901/2 4% Notes, 1913 „ ._ ._ *100fs Boston & New York Air Line 1st 4s, 1955 __ __ 95 Boston & Northern St. Ry. 4s, 1954 __ __ — 89 Boston & Providence 4s, 1918 __ __ 98 100 Boston & Worcester St. Ry. 1st 41/38, 1923 __ __ 91 96 Boston Rev. Bch. & Lynn 1st 41/28," 1927 __ __ 98I/2 _- Boston Terminal 31/2S, 1947 __ __ 901/2 93 Boyer Valley Ist SVgS, 1923 __ ._ 91 Braden Copper 7s __ 175 180 Braden Copper Conv. 6s, 1919 ... ._ *199i/2»210y2 Brandon Gas & Pow. 1st 6s, 1929 __ __ — *104 Brandram-Henderson 1st 6s, 1936 6%% basis Bremerton -Charleston Lt. & Fuel 6s, 1928 — — — *100 Bridgeport Gas Lt. 1st 4s, 1952 __ __ 92 •Quotation nearest March 1, 1913. No quotation on that date. 1090 High Low Bridgeton & Millv. 5a, 1930 Bristol Gas & El. 1st 5s, 1939 Broadway Realty 58, 1926 ^_ B'way & Seventh Ave. 5s, 1943 B'way & Seventh Ave. 5s, 1943 (Reg'd) Broadway & Seventh Av. 2nd 5s, 1914 Broadway Surface R. R. 1st 5s, 1924 Brockton Gas Lt. 1st 5s, 1928 Bronx Gas & Elec. 5s, 1960 Brooklyn, Bath B. & W. E. 5s, 1933 Brooklyn, Bath B. & W. E. 5s, 1917 Bklyn. Borough Gas 5s, 1945 Bklyn. Borough Gas 5s, 1938 Brooklyn City & Newt. 1st 5s, 1939 Bklyn. City R. R. Cons. 5s, 1941 Bklyn. Ferry Cons. 5s, 1948 Brooklj-n Heights 1st 5s, 1941 Bklyn. & Montauk 2nd 5s, 1938 Bklyn. & N. Y. Ferry 1st 6s, 1911 Bklyn., Queens Co. & Sub. Cons. 5s, 1941 Bklyn., Queens Co. & Sub. 1st 5s, 1941 Bklyn. Rap. Tran. 5s, 1945 Bklyn. Rap. Tran. Ref, 48, 2002 Brooklyn Rap. Trans. 5s, 1918 Bklyn. Union Elev. 1st 5s, 1950 Bklyn. Union Elev. 1st 5s, 1950 (stpd. guar.). Bklyn. Union Gas 1st Cons. 5s, 1945 Brooks-Scanlon Lumber Co. 1st 6s, 1916 Brownsville Av. 5s, 1926 Brownsville & Matamoras Bridge 1st 5s, 1930 Brunswick & Western 1st 4s, 1938 BufiFalo, Bellevue & San. 53, 1927 Buffalo City Gas Ist 5s, 1947 Buffalo Creek Ist 5s, 1941 Buffalo Gas 1st 5s, 1947 Buff. Gen. El. 1st 5s, 1939 Buff. Gen. El. 1st Ref. 5s, 1939 Buffalo Iron 5s, 1925 Buffalo & Lockport 1st 5s, 1938 Buffalo, Lockp, & Roch. 1st 5s, 1954 Buff., N. Y. & Erie 1st 7s, 1916 Buffalo & Niag. Falls Elec. 1st 5s, 1935 Buffalo & Niag. Falls Elec. 2nd 5s, 1921 Buff. & Niag. Falls El. Lt. & Pr. 1st 5s, 1942— Buffalo Ry. 1st 5s, 1931 Buffalo Ry. Deb. 6s, 1917 Buffalo, Rochester & Pittsburgh R. R. Equip. 41/28 Ser. E, 1922 Equip. 41/28 Ser. F, 1927 Equip. 4s Ser. G, 1929 Gen. 58, 1937 Cons. 41/28, 1957 Roch. & Pits. 6s, 1921 Roch. & Pitts. 6s, 1922 Equip. 41/2S "D," 1919 Buff. & Southw. 1st 5s, 1918 Buff. & Southw. 2nd 58, 1918 Buff. & Susq. Iron deb. 5s, 1926 Buff. & Susq. Iron 5s, 1932 'Quotation nearest March 1, 1913. No quotation on that date. 1091 Bid Asked 98 99 87 *98 103% 102 99 100 ^101 ' *103 30 99 101 97 101 *96 96 981/a *96 *98y3 99 101 1011/2 1021/4 12 101 103 ^102 85 90 981/^ *99 1021/4 1021/3 881/4 88% 961/2 96% 100% 101 100% 101 105 105% ' *100 99 1011/3 •100 91 __ 100 50 55 102 50 55 103 __ 1001/3 65 75 98 100 __ ♦73 107 110 103 104 102 __ 99 1031/2 105 1041/2 — »101 4%% 472% 4%% 41/2% 109 1093/4 10414 1041/a 1101/4 -.-. 112 *101 102 102% 95 85 97 __ Buffalo & Susquehanna R. R. — 1st & Ref. 4s, 1951 Equip. 5s "C," 1917 1st 41/28, 1953 Buffalo Trac. 1st 5s, 1948 Burl., Ced. Rpds. & N. 1st 5s, 1934 Burl. Gas Lt. (Vt.) 1st 5s, 1955 Burlington & Mo. (Neb.) Con. 6s, 1918 Burlington Ry. & Light 1st 5s, 1932 Burns (P.) Co. 6s, 1924 Burns (P.) 1st & Ref. 6s, 1931 Bush Terminal 1st 5s, 1952 Bush Terminal Cons 6s, 1955 Bush Terminal Bldgs. 5s, 1960 Business Real Estate Tr. 1st 4s, 1921 Butte El. & Pow. 1st 5s, due serially Butte Elec. & Pr. 5s, 1951 Cahaba Coal Mining 1st 6s, 1922 Calgary Brew. & Malting 1st 5s, 1942 Calgary Power 1st 5s, 1940 CaUf. Cable R. R. 1st 5s, 1915 Cal. Cent. Gas & Elec. 5s, 1931 Calif. Elec. Gen. 1st 5s, 1948 Cal. Gas & Elec. (Gen. Mtge. & C. T.) 5s, 1933 Calif. Gas & El. Un. & Ref. 5a, 1937 California Northwestern 1st 5s, 1928 California St. Cable Co. 5s, 1920 California Wine Ass'n 5s, 1925 Calumet & Copper Creek 6s Calumet & So. Chic. 1st 5s, 1927 Camaguey Co. 1st 5s, 1946 Cambria & Clearfield 1st 5s, 1941 Cambria & Indiana R. R. 1st 5s, 1936 Camden & Rockland Water 4s, 1925 Camden Suburban 1st 5s, 1946 Cameron Lumber 1st 6s, 1916-22 Canada Bread 1st 6s, 1941 Canada Cement Ist 6s, 1929 Canada Southern Cons. 58, 1962 Canada Starch 6s, 1930 Canadian Car & Foundry Ist 6s, 1939 Cnadian Cons. Felt 1st 6s, 1940 Canadian Cons. Rubber 6s, 1946 Canadian Cottons 1st 5s, 1940 Canadian Interlake Line 1st 6s, 1927 Canadian Lt. & Pow. 1st 5s, 1949 Canadian Locomotive 1st 6a, 1951 Canadian Northern Ry. — "D" 4V^s Equip. «G" 4y2S Equip. «F-1" 41/28 Equip. «E-1" 41/2 4s, 1919 Deb. 4s, 1939 Can. Nor. 48, 1929 Imp. Roll. Sk. 41/28, 1922 Winnipeg Ter. 41/2S, 1932 'Quotation nearest Marcb 1, 1913. No quotation on that date. 1092 High Low Bid Asked 381/2 •100 10 15 104 __ 109% 94 951/, 102 1021/2 941/2 961/2 103 104 100 101 __ 89 94 96 97 •99 931/2 94% 9!> 97y2 •1031/2 •110 •85 •921/2 101 101% 103 82 841/, 101% 951/2 953/4 •104 101 102 98% •70 97 981/2 •88 1011/2 __ *95 •95y, 105 106 ' •101 •871/2 99% IO6I/2 1071/a 100 __ 105 •98y, 93 94 803/4 81 *100 76% — 100 5% basis ._ •99.29 5% basis -_ ♦lOO 100 95 __ 95 . 51/4% 51/4% 5% High Low Bid Asked Canadian Pacific Ry. — 1st Deb. 5s, 1915 __ Cons. Deb. Perp. 4s Aroostook Valley 41/38, 1929 New Brunswick 1st 5s, 1934 New Bninswick Cons. Perp. 4s Canadian Puget Sound Lumber 6s, 1915-21 Canadian Puget Sound Saw Mills 1st 6s, 1915 Canadian Venezuelan 1st 6s, 1927 Canal & Clairborne R. R. 1st 6s, 1946 *12iyz — Canton & New Phila. 5s, 1923 Canton-Akron Ry. 1st 5s, 1932 Canton-Akron Cons. Ry. Cons. 5s, 1933 Canton Elec. 1st & Ref. 5s, 1937 Canton Massillon Ry. 1st 58, 1920 Cape Breton Coal, Iron & Ry. 1st 5s, 1933 Cape Breton Elec. 1st 5s, 1932 Capital Traction 5s, 1947 Carbondale & Shawneetown 1st 4s, 1932 Carbondale Ry. 5s, 1933 Carolina Central 1st Cons. 4s, 1949 Carolina, Clinchfield & Ohio 1st 58, 1938 Carolina Power & Light 1st 5s, 1938 Carolina Terminal 1st 5s, 1937 Carolina & Yadkin River 1st 5s, 1962 Carondelet Bridge 1st 41/28, 1938 Carthage & Adiron. 1st 4s, 1981 Carthage, Watert'n & Sack. Har. R. R. 5s, 1931 Carlton Cons. Lumber 1st 6s, 1921 Cass Ave. & Fair Grounds Ext. 4l^s, 1922 Caswell Hotel 1st 5s, 1915 Cataract Pow. & Cond. 1st 5s, 1927 Catawba Power Ist 6s, 1933 Catawissa R. R. Cons. 4s, 1948 Catlettsb'g, Ken. & Ceredo Wat. Cons. 5s, 1933 Cedar Rap., la. Falls & Northw'n 1st 5s, 1921 Cedar Rpids & M. 1st 7s, 1916 Central Ark. & Eas. 1st 5s, 1940 Central Branch Ry. 1st 4s, 1919 Central Branch (U. P.) 1st 4s, 1948 Central Calif. Gas 1st 6s, 1932 Central Calif. Traction Co. 58, 1936 Central Coal & Coke Gen. & Cons. 6s, 1913-25 Central Colorado Power 5s, 1946 Central Crosstown 1st 6s, 1922 Central Electric 5s, 1914 Central Georgia Power 5s, 1939 Central Hudson Steamboat 5s. 1919 Central Hlinois Pub. Serv. Ist & Ref. 5s, 1952 Central Hlinois Utilities 1st 6s, 1916-32 Central Indiana Ry. 1st 48, 1953 Central Leather 5s, 1925 951/3 951/2 Central Maine Power 5s, 1939 Central Maine Power 5% Notes, 1915 Central Market 1st 5s, 1922 Central Mass. Elec. 1st 6s, 1924 Central Mex. Lt. & Pow. 1st 68, 1940 Central National Bank (Cleveland) *168 Central New England 48, 1961 90i4 9014 'Quotation nearest March 1. 1913. No quotation on that date. 109S 101 103 991/3 1001/2 97 100 107 109 97 99 ♦100 ♦981/3 ~ ♦93 95 98% 97% 99 ♦921/3 951/3 971/3 97 99 ♦90 951/3 110 111 90 _ 95 971/3 91% 95 100 901/2 931/3 ♦99 __ ♦911/3 95 100 88 *1083/4 __ »100 96 96% 51/2% 1011/3 ♦101 981/2 991/3 95 1011/2 106 107 108 971/3 91% 771/2 __ 100 95 *100 ^30 fl. 104 __ 93 96 *80 98 100 95 ■' »100 87 ~ 97 99 •991/4 96 97 ♦99 83 86 High Low Bid Asked Central N. Y. Gas & Elec. 5s, 1941 __ __ *93i/2 ~ Central N. Y. Gas & Elec. 6% Notes, 1916 __ __ __ ♦100 Central of Georgia Ry. — Cons. 5s, 1945 ._ __ 106% 107 1st 58, 1945 __ __ 110 Chatt. Div. 4s, 1951 __ __ __ 90 Macon & Nor. 5s, 1946 __ __ *105y8 __ Middle Ga. & Atl. 5s, 1947 __ __ *105y8 ._ Equip. 41/2S, Series «H," 1916 __ __ 51/8 4% Equip. 41/28, Series "I," 1917 __ __ SVs 4% Equip. 41/38, 'Series "K," 1917 __ __ 51/3 4% Mobile Div. 5s, 1946 __ __ 106 108 Oconee Div. 1st 5s, 1945 __ __ 106 108 Eatonville Br. 5, 1926 __ __ 100 Central Ohio R. R. 1st Cons. 41/38, 1930 __ __ 100 Central Pacific 1st Ref. 48, 1949 __ __ __ 95 Central Pacific 1st Ref. 31/2S, 1929 __ __ __ 9014 Central Pacific Thro. Sht. Line 1st 4s, 1954__ __ __ __ 9214 Central R. R. & Bkg. of Ga. Col. 5s, 1937 __ __ __ 101% Central R. R. of Haiti 1st Coll. 6s, 1919 __ __ ♦95 *100 Central R. R. of N. J. Gen. 58, 1987 __ __ 1171/3 118% Central R. R. of N. J. Col. 4s, 1951 __ ._ __ 96I/3 Central R. R. of N. J. Equip. 4s, April, 1913— __ __ 99% __ Central R. R. of South Carolina 6s, 1921 __ __ 110 Central Ry. Con. 58, 1932 __ __ 107 108 Central Ry. Ext. Imp. 5s, 1932 >_ __ 105 107 Central States Elec. 5% Notes, 1922 __ __ __ *94i/2 Central Terminal 1st Chic. Term. 48, 1941 __ __ 95 961/2 Central Traction 1st 5s, 1929 __ __ 102 103% Central Union Gas 5s, 1927 __ __ 102 103 Central Vermont 1st 4s, 1920_I __ __ _> 89 Central Vermont Equip. 5s, 1915 __ __ __ ^10014 Central Vermont Equip. 5s, 1917 __ __ _, ♦lOO^ Central Vermont Equip. 5s, 1918 — -_ — MOOyg Cent. Vermont Trans. "B" 5s, 1921 _. __ ♦100%^100% Centralia & Chehalis Gas 1st 51/2S, 1930 __ __ __ ♦lOO Chadwick Brass 1st S. F. 6s __ __ __ 971/3 Champaign & Urbana Wat. 1st 5s, 1932 __ __ __ 98 Champaign Lumber 1st 6s, 1914-28 __ __ __ ♦lOO Charleston & Sav. 1st 7s, 1936 __ __ *127% — Charleston & West. Car 1st 5s, 1946 __ __ 105 106 Charleston City Ry. 1st 5s, 1923 _> __ 103 104 Charleston Cons. Ry. & E. 5s, 1999 «._ _. 951/2 97 Charleston Gas & Elec. 1st 5s, 1922 __ __ ♦821/2 __ Chateaugay Ore & Iron 4s, 1942 __ — 85 Cliattahoochee & Gulf 5s, 1930 __ — 100 Chattanooga Elec. Rys. 1st 5s, 1919 __ -_ 'lOO^ __ Chattanooga Gas 1st 53, 1927 -_ __ 96 Chattanooga Rys. 1st Cons. 5s, 1956 __ __ ♦951/3 ♦§? Chattanooga Ry. & Lt. 1st & Ref. 53, 1956 >_ __ 93 96 Chatt., Rome & Sou. 5s, 1947 _ 105 Chattanooga Station 1st 4s, 1957 __ _« 88 91 Cherry Riv. Boom & Lumber 1st Ref. 5s, 1929_ __ __ ♦99i/2»100% Clies.'& Del. Canal 1st 5s, 1916 ._ _. __ 66 Chesapeake & Ohio Ry. — Car Tr. Ser H 4s, 1916 „ „ 5% 4%% Coll. Notes 41/2S, 1914 98% 9914 R. & A. Div. 1st 4s, 1989 __ >_ ^91% ^94 R. & A. Div. 2nd 4s, 1989 __ _. 88 "Quotation nearest March 1, 1913. No quotation on that date. 1094 High Low Elevator Co. 4s, 1938 Conv. 41/28, 1930 -_ 90% 90% Gen. 5s, 1929 Com. 5s, 1939 __ " __ Gen. 4s, 1939 41/28, 1993 IGOVs lOOi/s Craig Valley 5s, 1940 Potts Creek 4s, 1946 Warm Springs Valley 1st 5s, 1941 dies. & Pot. Tel. 5s, 1909-29 Ches. S. S. 1st Equip. 58, 1914-24 Chester Co. Gas 1st cons. 58, 1925 Chesterfield & Lancaster 1st 5s, 1955 Chester Water 1st 5s, 1921 Chicago & Alton R. R. — Deb. 5s, 1922 5% Notes, 1915 Eq. Assn. 4s, 1915 Eq. Assn. 4s, 1914 Impt. & Equip. 5% Notes, 1913 1st Lien 31/28, 1950 Ref. 3, 1949 Chic. & Atl. Term. 5s, 1918 Chic. Athletic Assn. 5s, 1926 Chic. Audit. 1st 6s, 1929 Chic. B'd of Trade 5s, 1927 Chicago, Burlington & Quincy R. R. — Jt. 4s, 1921 Gen. 4s, 1958 Den. Div. 4s, 1922 111. Div. 31/28, 1949 111. Div. 4s, 1949 la. Div. 58, 1919 la. Div. 4s, 1919 Neb. Div. 4s, 1927 58, Deb. Mar., 1913 S. W. Div. 4s, 1921 Oiic. City & Conn. Coll. 5s, 1927 Chic. City Ry. 1st 5s, 1927 Chicago & Eastern Illinois R. R. — Equip. 58, 1922 «E" 41/2S, 1915 1st Cons. 6s, 1934 Gen. Cons. 1st 5s, 1937 P. M. 1st 5s, 1942 Ref. 43, 1955 1st Extn. 6s, 1931 Chic. El. Ry. 5s Notes, 1914 Chic. & Erie 1st 5s, 1982 Chic. Gas Lt. & Coke 5s, 1937 Chicago Great Western R. R. — Ist 4s, 1959 1st 5s, 1960 Ist Terra. 5s, 1936 Chic, Hammond & West. 6s, 1927 ____ Chica!?o & Ills. Coal Ist 5s, 1936_ Chic. & Ind. Coal Ry. 1st 5s, 1936 Chic, Ind. & So. 4s, 1956 Chic, Inpts. & Louis. Equip. 41/3S, 1915 'Quotation nearest March 1, 1913. No quotation on that date. lOOS Bid . A.sked 80 — "" 101 108% 109 101 — 101% :: 80 101 105 1051/2 — ♦100 *98i/2 ^ *100 97 100 — ■ *100 85 92 991/4 100 4%% 4%% ♦991/4^ *100 60 611/2 68 70 98 100 ♦96 ' *101 90 94 97 99 94% 95 J)4i/2 95 99 991/2 841/4 85 96 971/3 1031/4 104 981/2 991/4 96% 100 100 100% 981/4 81% 851/2 1011/4 1011/2 5% 4% 5y4 4% 118 120 105 107 971/2 751/4 76 -_ ^1191/, 971/4 97% 1101/2 102% 1031/2 751/s 76 ^100 __ 1021/2 __ 115 118 104% __ 104% __ 91 51/4 4% High Low Bid Asked Chic, Inpls. & Louis. Equip. 4VsS, 1921 Chic, Indpls. & Louis. Ref. 4s, 1947 Chic, Indpls. & Louis. Ref. 5s, 1947 Chic, Indpls. & Louis. Ref. 6s, 1947 Chic, Ind. & St. L. (Short Line) 1st 4s, 1953_ Chicago Junction let 4s, 1945 Chic June Ry. & Stk. Yds. 5s, 1915 Chic. Jen. Rys. & Stk. Yds. Ref. 4s, 1940 Chic, Lake Shore & Eastern 1st 41/28, 1969— _ Chic, Mera. & Gulf 1st 5s, 1940 Chicago & Mil. Elec Ry. 53, 1919 Chicago & Mil. Elec R. R. 1st 5s, 1922 Chic & Mil. Elec R. R., Wis. Div., 1st 58, 1925 Chicago, Milwaulcee & St. Paul Ry. — Terminal 5s, 1914 Wis. & Minn. 5s, 1921 Wis. Valley 6s, 1920 4s, 1925 971/2 971/2 Deb. 43, 1934 . 90 Sdy^ Gen. A 4s, 1989 Gen. B 31/2S, 1989 Conv. 41/2S, 1932 102^/8 102 Chic & Lake Sup. 5s, 1921 Chic & Mo. Riv. 5s, 1921 Chicago & Pacific West. 58, 1921 IO41/2 IO41/2 Dubuque 6s, 1920 La. Cr. & Davenpt. 5s, 1919 Chic, Mil. & Puget Sd. 4s, 1949 94 94 Chicago & North Michigan 1st 5s, 1931 Chicago & North Western Ry. — Cons. 7s, 1915 Marshfield Ex. 1st 5s, 1922 ■— Equip. "A" 41/2S, 1914-22 Equip. "B" 41/28, 1913-22 5s, 1929 6s, 1929 Gen. 4s, 1987 Ext. 4s, 1926 Gen. 31/2S, 1987 84 84 Deb. 5s, 1921 Deb. 53, 1933 Mil.-Ashland 6s, 1925 Chic, Peoria & St. L. P. L. 41/28, 1930 Chic PneuTn. Tool 5s, 1921 Chicago Railways Co. — 1st 5s, 1927 — Cons. "A" 5s, 1927 Cons. **B" 5s, 1927 Cons. "C" 5s. 1927 Pur. M. 4s, 1927 Adj. Inc 4s, 1927 Chic & Rock Island Elev. 1st 5s, 1912-24 Chicago, Rock Island & Pacific Ry. — Deb. 58, 1932 — * — Gen. 4s. 1988 Ref. 4s, 1934- 86% 86% 4s, 2002 Equip. 41/28, 1917 Equip. 4y2S, 1919 'Quotation nearest March 1, 1913. No quotation on that date. 1096 5V4 4% 90 901/8 105 108 126 90 90 92 991/2 9978 87 103 *97 ' »1033/4 99 1021/, 48 51 17 20 1001/4 ._ 1033/4 104% 1101/2 112% 97 971/2 83% 84 loi 1051/2 1051/2 ~ 1105/8 __ 102% — 90 — 105 105% 104 ♦45/8% __ ♦4.70 103 1031/3 108 108% 961/2 97% 96 ~ 101 103 IO6I/3 1071/2 1141/4 __ 91 __ 93 94ya 991/2 99% 95% 831/4 83y2 94y2 70% 73ya 47 51 — •99 86 87 92% 933/8 63 631/2 51/2-5% basis 51/2-5% basis High Low Bid Asked Equip. 41/28, 1925 — — 51/2-6% basis Is, 1917 ^ — — 1061/8 — Coll. 4&, 1918 -- — — 51^% Coll. "K," 1913 -_ — 97 Coll. "P," 1918 __ — — 95 Chic. & St. Louis 1st 6s, 1915 — __ lOSi/g — Chic, St. L. & N. O. Cons. 5s, 1951 __ __ __ 112% Chgo., St. L. & K 0. Cons. 31/3S, 1951 Chgo., St. L. & N. 0. Memp. Div. 4s, 1951 Chic, St. L. & Pitts. Con. 5s, 1932 Chic, St. P. & Minn. 1st 6s, 1918 Chicago, St. Paul, Minn. & Omaha Ry. — Cons. 6s, 1930 120 120 Cons. SYgS, 1930 Deb. 5s, 1930 Chic, So. Bend & Nor. Ind. 1st 5s, 1937 Chic Telephone 1st 5s, 1923 Chicago Term. C. & G. W. 5s, 1936 Chic, Terre Haute & S. E. Ist 5s, 1960 Chic, Terre Haute & S. E. Inc. 5s, 1960 Chic Utilities 1st A. & B. 5s, 1942 Chicago & Western Indiana R. B. — Cons. 4s, 1952 Gen'l 6s, 1932 3-vr. 5% Notes, 1915 Chic & West Mich. By. 5s, 1921 Chic, Wilm. & Verm. Coal 1st 6s, 1931 Chicago, Wis. & Minn. 1st 6s, 1916 Chino Copper 6s, 1921 155 155 Chippewa Val. By., Lt. & P. 1st 5s, 1924 Choctaw & Memphis 5s, 1949 Choctaw, Okla. & G. Gen. 5s, 1919 Choctaw, Okla. & G. Cons. 58, 1952 Choctaw Bv. & Ltg. 5s, 1938 Cicero Gas Bef. 5s, 1932 Cin., Daytcn & Chic. 1st 4s, 1942 Cine, Dayton & Ironton 1st 5s, 1941 Cin.. Day. & Tol. Tr. 5s, 1922 Cin. Edison Elec 58, 1917 Cine, Findlay & Ft. W. 1st 4s, 1923 Cin, Gas Transp. 5s, 1933 Cin. Gas Tranap. 5s (guar. Cin. Gas Co.) Cincinnati & Ham. Elec St. By. 6s, 1918 Cincinnati, Hamilton & Dayton By. — 2nd 41/oS, 1937 1st 4s, 1959 P. M. Coll. Tr. 4s, 1913 41/38, 1939 5s, 1942 4s, fixed Gen. Gtd. 4s. 1939 Cin., Indpls.. St. L. & Chic Cons. 6s, 1920 Cin., Ind., St. Louis & Chic 1st 4s, 1936 Cine, Indpls. & West. 1st 4s, 1953 Cine, Ind. & St. L. Short Line 1st 4g, 1953 Cine, Law. & Aur. 5s, 1919 Cin., Lebanon & Nor. 5s, 1916 Cin., Lebanon & Nor. By. 4s, 1942 Cine * Muskingum Val. 1st 4s, 1948 •Quotation nearest Maxch J, 1913. No quotation on that date. 1097 80 __ 89 —-. 107 Ill 419 ~ 120 1211/4 10114 102l^ 77 79 101 101 99 951/4 __ •66 — 61 87 881/, 106% •99% *99% 951/2 99 i »104 101 — ♦94 ■" 107 107^4 1001/2 97 100 ♦67 98 ♦83 __ 991/4 85 1003/8 101 87 88 91 100 1011/2 110 95 1011/4 911/8 ♦99% ♦99% 65 67 98 105 7472 76 ♦691/2 __ 1051/4 __ 931/s __ 86% 92 __ 90 101 921/2 95 88 94 High Low Bid Asked Cine, N. O. & Texas Pac. Equip. 41/28, 1916__ __ >_ 48^ 514 Cine, N. O. & Texas Pac. Equip. 41/28, 1921__ __ __ 4% 514 Cin., Newp. & Gov. Lt. & Tr. Ist 5s, 1922 __ __ lOlVg 105 Cin., Newp. & Gov. Lt. & Tr. 2nd 5s, 1922 __ __ 100l^ 104 Ginc. Northern 1st 4s, 1951 __ __ 84 89 Cine., Rich. & Ft. W. 7s, 1921 __ ._ 112 Cine, Sand. & Gleve. 1st Cons. 5s, 1928 >_ __ 'lOS Cin. Trac. Equip. "C" 5s, 1912-21 __ __ __ ♦101 Cin. Trac. Equip. "D" 5s, 1913-22 __ __ ._ 'lOl Cine, Wab. & Mich. 1st 48, 1991 __ __ 88I/2 90 Citizens Gas (Indpls.) 1st Ref. 5s, 1942 __ ._ __ *101 Citizens Gas (Kankakee) 1st 5s, 1932 __ __ *97 atizens Gas & El. Cons. 6s, 1931 __ __ __ 96 Citizens Gas & Fuel Ist & Ref. 5s, 1960 __ __ 94 96y, Citizens Gas Light 1st 5s, 1940 __ _. __ '104 Citizens Gas & Wat. 1st 5s, 1926 : __ __ *95 "gs Citizens Ind. Tel. (T. H.) 1st 5s, 1936 __ __ __ 87 Citizens Lt., Ht. & Pr. 1st 5s, 1934 __ __ 991/2 101 Citizens R. R. (Ind.) 1st 5s, 1933 _- __ *100y2*102i/a Citiz. Ry. & Lt. (Muscatine, la.) 1st 5s, 1917_ __ __ 97 100 Citizens Ry., L. & P. (Newport News) 5s, 1940 __ __ 79 Citizens Street Ry. Cons. 5s, 1933 101 101% Citizens Street Ry. (Memphis) 6s, 1916 __ __ IO21/2 104 Citizens Trac. (Pitts.) lat 5s, 1927 __ __ 1021/2 105 Citiz. Tr. of Venango Co., Pa., 1st S. F. 5s, 1942 __ __ __ *99 Citizens Wat. Supply (Newtown) 2nd 4s, 1921 „ __ *78 City & Suburban 6s, 1916 „ __ 101 105 City & Suburban Cons. 4s, 1930 __ __ 89 92 City & Suburb. R. R. Bait. Ist 5s, 1922 — ._ 103% IO434 City & Suburban 5s, 1948 __ __ 103 IO41/4 City Electric 1st 5s, 1937 — _. 86^3 871/4 City Gas (Norfolk) 1st 6s, 1926 __ — *105 City Gas & Elec. 1st 5s, 1935 _ 79 City Realty Inv. Conv. 5s, 1927 __ __ __ ♦971/2 City Water Power 1st 5s, 1939 __ — >_ 98i/a Clairton Steel 5s, 1913 __ __ _, lOOi/g Clearfield & Jefferson 6s, 1927 — — — 117 Clearfield & Mahoning 1st 5s, 1943 __ _- 105 Clearf. Bit. Coal Co. 1st 4s, 1940 __ __ 75 80 Cleve., Akron & Col. 5s, 1927 -_ __ 103 108 Cleve., Akron & Col. 1st guar 4s, 1940 __ _. 88 Cleve., Akron & Col. Unguar. 4s, 1940 __ __ 88 Cleve., Berea, Elyria & Oberlin Cons. 5s, 1919- __ __ ♦lOO Cleveland, Cine, Chicago & St. Louis Ry. — 41/2S, 1931 -_ — 911/8 91% Gen. 4s, 1993 90% 90% 1st 4s, 1939 — — 90 911/a St. Louis 1st 4s, 1990 90 90% Sprgfld. & Col. Div. 1st 4s, 1940 •87 White W. Valley Div. 4s, 1940 — — ^87 Cleve., Col., Cine & Inpls. Cons. 7s, 1914 — __ __ 105 Cleve., Col., Cine & Inpls. Cons. S. F. 78, 1914 — — t02 Clece., Col., Cine & Ind. 63, 1934 __ — 120 124 Cleve. Elec. Ilium. 1st Ref. 5s, 1939 __ — 101 102 Cleveland & Elyria 6s, 1915 100 Cleve., Elyria & West. Cons. 5s, 1920 ^95 Cleve., Lorain & Wheeling 1st 5s, 1933 __ __ 100 Cleve., Lorain & Wheeling Cons. 41/2S, 1930 — __ 92 Cleve. & Mahoning Valley 5s, 1938 — — — 109% ♦Quotation nearest Blareh 1, 1913. No quotation on that date. 1098 High Low Cleveland & Marietta 1st 41/28, 1935 Cleve., Painesv. & Ash. os, 1922 *72% _- Cleveland, Painesv. & E. 5s, 1916 Cleveland, Painesv. & E. 58, 1918 Cleveland & Pitts. Gen. 41/38, Ser. A, 1942 Cleveland & Pitts. Gen. 41/2S, Ser. B, 1942 Cleve. & Pitts. Gen. 41/28, Red. to 31/2S, 1942__ Cleveland & Pitts. Gen. 31/38, Ser. C, 1948 Cleveland & Pitts. Gen. Si/gS, Ser. D, 1950 Cleveland Ry. 5s, 1931 *101l^*101l^ Cleve. & Sand. Brew. 68, 1948 *83 *83 Cleve. & S. W. Trac. Cons. 5s, 1923 *90l^ *90i4 Cleve., S. W. & Col. 5s, 1927 -, *83 *83 Cleve. Term. & Valley 1st 48, 1995 Clyde S. S. 1st 5s, 1931 , Coal & Coke By. 58, 1919 Coal & Iron By. 5s, 1920 Coal Biver By. 1st 48, 1945 Coast Counties L. & P. 5s, 1946 Coast Vys. Gas & El. 1st 6s, 1952 Collegiate Bealty 1st 5s, 1922 Colorado Fuel Gen. 6s, 1919 Colo. Fuel & Iron Gen. 5s, 1943 Colo. Indust. 5s, 1934 Colo. Midland By. 1st 4s, 1947 Colorado Power 5s, 1953 Colorado Power 5s, 1936 Colorado Biver Bridge 1st 7s, 1920 Colo. So., N. O. & Pac. Equip. 5s Colorado & Southern By. — < 1st 4s, 1929 92% 92% Extd. 41/2S, 1935 Colo. Spgs. & Cripple Crk. Dist. 1st 5s, 1930-_ Colo. Spgs. & Crip. Crk. Dis. 1st Cons. 5s, 1942 Colo. Spgs. Elec. 1st 5s, 1920 Colo. Spgs. Lt. & Pow. 1st 5s, 1919 Colo. I^rgs. L, H. & P. 1st & Bef. 5s, 1920 Colo. Yule Marble 1st 6s, 1915-20 Columbia & Greenville Ist 68, 1916 Columbia & St. Louis Ist 48, 1942 Columbia Gas _ __ *99i/2 — Dighton, Somerset & Swansee St. Ry. 5s, 1915 „ „ -_ *98% Distillers Secur. 53, 1927 ._ — 68 69l^ Dist. of Columbia Paper Mfg. 5s, 1910-40 — __ 90 100 Doe Run Lead 6s, 1915 *99i/2 — Dolese & Shepard Gen. 6s, 1930 — __ — *90 Dominion Canners 6s, 1940 — — *10iy2*103 Dominion Coal 1st 5s, 1940 _- __ 99 Dominion Cotton Mills 2nd 6s, 1922 __ — 'lOl *10iya Dominion Iron & Steel 5s, 1929 — __ 91 911/3 Dominion Nat. Gas 6s, 1915 >- __ — "lOOi/a Dom. Pow. & Trans. 1st 58, 1932 __ __ __ 98 Dominion Sewer Pipe 6s, 1927 — __ — *100 Dominion Steel Deb. 5s, 1915 — _- *5%% basis Dorer Gas Lt. Cons. 5s, 1925 — — •4.90% basis Drake Hotel 1st 5s, 1933 __ __ __ ^95 Dry Dock, East B'way & Battery 1st 5s, 1933 — _> 100 105 Dry Dock, E. By. & Batt. Certif. Ind. 5s, 1914 __ __ 32 40 Du Bois Elec. & Tr. 5s, 1932 __ __ _» 90 Duluth Edison 1st 5s, 1931 __ __ 95 Duluth & Iron Range 1st 5s, 1937 — __ 100 103% Dul. & Ir. Range 2nd 6s, 1916 >_ _- 101l^ — Duluth, Missabe & Nor. 1st 6s, 1922 __ __ 95 Duluth, Missabe & Nor. 1st Con. 6s, 1923 „ — 104 Dul., Missabe & Nor. Ry. Gen. 5s, 1941 __ __ — 105 Duluth, Rainey Lake & W. 1st 5s, 1916 — __ 99 99ya Duluth Short Line 1st 5s, 1916 __ __ 991/3 >- Duluth, So. Shore & Atl. 1st 5s, 1937 „ -_ 103 107 Duluth Street Ry. Ist 5s, 1930 __ __ 99 99% Duluth Street Ry. Gen. 5s, 1930 __ __ ♦991/2 _- Duluth Union Depot Deb. 5s, 1930 ._ __ 100 Dunkirk & Fredonia Tr. 1st 5s, 1962 __ — *96 Dunlop Tire & Rub. 1st 68, 1927 — — — *98 DuPont 41/2S, 1936 87 87 DuPont Internat. Pow. 5s, 1922 — — *97 DuPont Internat. Pow. Coll. 5s, 1934 — — '97 Duquesne Traction 1st 5s, 1930 — — 102 1021/3 •Quotation nearest March 1, 1913, No quotation on that date. 1103 High Low Bid Asked Durham Trac. 1st 5s, 1941 — — — *100 Dutchess County 4y2S, 1940 100 103 Eagle & Phenix Mfg. 5s, 1936 ~ — 93 98 East Chic. & Ind. Harb. Water 5s, 1927 — — *91i/2 __ East End El. Lt. Ist 6s, 1915 — — •lOliA __ East Liverpl. Tr. & Lt. 1st 5s, 1925 — — 64 70 East McKees. St. Ry. 1st 5s, 1929 — — — *100 East Ohio Gas 1st 5s, 1939 — — 98 100 East Penn. Gas & Elec. 1st 5s, 1942 — — — 96 East St. Louis & Interurban 5s, 1932 — — 94 96 East St. Louis & Suburban Ss, 1932 — — — *97 East St. Louis Gas Lt. 5s, 1922 — - 99% lOOi/o East Tenn, Va. & Ga. 5s, 1930 — — 105 East Tenn., Va. & Ga. Cons. 5s, 1956 — — 108 1083^ East Tenn. & West No. Car. Ist 5s, 1935 __ — — *10iy2 Eastern Car Co. 1st 6s, 1952 — — — *102 Eastern Mfg. 1st 5s, 1914-33 — — *5.38% basis Eastern Michigan Edison Ist 5s, 1931 — — 96y2 100 Eastern Oregon Lt. & P. 1st & Ref. 6s, 1929-_ __ __ — 100 Eastern Penna. Pow. 1st & Ref. 5s, 1939__^__ __ — *93 *96y2 Eastern Penna. Rys. 1st 53, 1936 __ — 7iy2 73y2 Eastern Ry. of Minn., North Div., 1st 4s, 1948 __ _. 92 97 Eastern S. S. 1st 58, 1927 __ — 100 102 Eastern Steel 1st 5s, 1931 — __ 84 88 Eastern Texas Elec. 1st Coll. 5s, 1942 — — — 94 Eastern Wise. Ry. & Lt. 1st 5s, 1923 „ — 95 97 Easton & Amboy 5s, 1920 __ „ 104 106 Easton Cons. Elec. 5s, 1949 >_ __ 98 100 Easton, Palmer & Beth. 1st 5s, 1918 __ __ 99 100 Economy Lt., Ht. & Pow. 1st 5s, 1930 — __ *96 *100 Economy Lt. & Power 1st 5s, 1956 __ — 97y2 100 Eden Irrig. & Land Co. 6s __ ._ — *60 Edgefield Street Ry. Con. 6s, 1920 __ __ 106 lOSy^ Edison El. (Lancaster, Pa.) 1st & Ref. 5s, 1943 __ __ _. *97y2 Edison Elec. (Los Angeles) 1st Ref. 5s, 1922— __ — 101 102^} Edison Elec. (Los Angeles) 5s, 1929 __ __ 100 Edison Elec. (New Orleans) 5s, 1929 __ __ 103 Edison Elec. Dlum., B'klyn, 1st 4s, 1939 __ — SSYs — Edison Elec. Ilium, of N. Y. 1st 5s, 1995 ._ __ 108 111 Edison Elec. 111. of Paterson Cons. 5s, 1925___ __ __ __ *100 Edison Elec: Light (Phila.) 5s, 1946 __ __ 107 108 Edison Light & Power 6s, 1921 __ __ 106% __ Eighth Avenue Cert. Ind. 6s, 1914 __ __ 99 101 Elec. & Ppls. Trac. Tr. Ctfs. 4s, 1945 __ __ 84y2 85 Electrical Development 1st 5s, 1933 __ __ *96 *97 Electrical Secur. Coll. 5s, 1935 __ >_ 99 101 Electro Metallurgical 6s, 1937 »_ __ *102y2 __ Elgin, Aurora & So. Tr. 1st 5s, 1916 __ _.. *98y2 — Elgin, Joliet & East. 5s, 1941 __ _. 106y2 107y2 Elizabeth, Plain. & Cent. Jersey 1st 5s, 1950— __ __ 96 97y2 Elizabethtown Water, 4s, 191 __ __ __ *96y2 Elkin & Allegheny, 1st 6s, 1941 __ __ 98 100 Ellsworth Coal, 1st 5s, 1919-25 __ __ *99 Elmira Contl. & North'n, 1st 6s, 1914 __ __ 100 Elmira Contl. & North'n, 1st 5s, 1914 __ _> 100 100% Elmira Water, Light & R. R., 1st 5s, 1949 __ __ 97 100 Elmira Wtr., Lt. & R. R., 1st 5s, 1956 __ __ 93 95 Elmira & Williamspt., 1st Ex. 4s, 1950 __ __ 97Va _- •Quotation nearest March 1, 1913. No quotation on that date. 1104 Elmira & Williamspt., Inc. 5s, 2863 El Paso Elec, Ist Con. 5s, 1933 El Paso Gas & El. Gen. 6s, 1934 El Paso & R. I., 1st 5s, 1951 Ely & Walker Dry Gds. Bldg., 5s, 1931 Elyria & Oberlin, 6s, 1917 Emerson Steam Pump, 6s, 1938 *65 Empire Dist. Elec, 1st 5s, 1949 Empire G. & El. Jt., 1st & Ref. 5s, 1941 Empire Pass. Ry., 1st Si/gS, 1930 Enid Elec. & Gas, 1st 6s, 1930 Enterprise Mfg., 51/28.. 1930 Equitable Gas, 1st 5s, 1939 Equitable Gas & Elec, 5s, 1943 Equit. Gas Lt., N. Y., Cons. 5s, 1933 Equit. Ilium. Gas Lt. (Phila.), 1st 5s, 1938 Equitable Mtge. & Tr., 5s, 1933 Erie Elec Motor, 6s, 1941 Erie Lighting, 1st 5s, 1943 Erie & Pittsburgh, "B" 31/28, 1940 Erie & Pittsburgh, "C" 31/2S, 1940 i:rie R. R.~ 1st Cons. P. L., 4s, 1996 1st Cons. G. L., 4s, 1996 Penn. Coll., 4s, 1951 Conv. "A," 4s, 1953 Conv. "B," 4s, 1953 Equip., 41/2S, 1931 Equip., "I" 4s, 1916 Equip., "N" 5s, 1917 Col., 6s, 1914 Col., 5s, 1914 Col., 5s, 1915 Buff. & S. W. Div., 3nd 5s, 1918 Erie Ry., funded 7s, 1930 Erie & Western Transp., 1st 4s, 1935 Escanaba Traction, 1st 5s, 1934 Estate of Long Beach, 1st 6s, 1917 Eureka Construction coll. tr. 6s, 1914-19 European & N. Am., 4s, 1933 Evansville & East. EL, 1st 5s, 1936 Evansville Elec, 1st 4s, 1931 Evansville Gas &, Elec. Light, 5s, 1933 Evansville, Hend. & Nash., 1st 6s, 1919 Evansville & Indpls., Ist Cons. 6s, 1936 Evans. & Indpls., 1st 6s, 1934 Evansville & Mt. Vernon El. Ry., 1st 5s, 1935— __ Evansville & Princeton Trac, 1st 5s, 1933 Evansville & Terre H., 1st Cons. 68, 1931 Evansville & Terre H., Ref. 5s, 1941 Evansville & T. H., Ist Genl. 5s, 1943 E. & T. H., Mt. Vernon, 1st 6s, 1933 E. & T. H. Equip. "C," 1916 __ Evans., T. H. & Chic, Inc., 6s, 1930 Everett Gas, 1st 5s, 1940 Everett Ry. Lt. & W., 1st Cons. 5s, 1935 Excelsior Spgs. W., G. & E. 1st 6s, 1933 •Quotation nearest March 1, 1913. No quotation on that date. 1105 High Low Bid Asked 110 113 97 100 *98i/2 101 97 99 100 — 86 89 97 98 •93 98 101 -1011/2 98 99 103 107 1061/, i noo 981/2 — •931/2 901/4 ~ 901/8 841/2 851/a 73 75 891/4 90 79 8OI/2 731/2 74 5-4%% basis 5iA-5%basi3 1001/3 1003/8 1003/4 991/4 993/4 981/2 99 •95 ♦114 971/2 99 •97 •76 *100 93 __ __ •89 85 88 931/2 96 ♦1101/2- •1111/3 106 1098/4 105 •58 •78 97 111 •80 99% 103 •107 4.90% basis 104 __ 85 100 98 100 High Low Bid Asked Fairmont & Clarksburg Tr. 1st 5s, 1938 -_ ._ *100y2»10iya Fairmont Coal 5s, 1931 __ __ 95 96 Fairmont Park Transp. 1st 5s, 1937 _> __ __ 96 Fargo & Moorhead St. Ry. 1st 5s, 1925 _> __ *92 Fargo & Southern 63, 1924 __ _. 1131/2 __ Federal Light & Trae. 1st 5s, 1942 __ >_ 92 94 Federal Publishing 1st 6s, 1920 >_ __ __ *100 Federal St. & P. V. 5s, 1942 __ __ lOlVg 102% Federal Sugar Refin. 5% Notes, 1914 __ __ 98 98% Federal Tel. (Buffalo) 5s, 1954 ._ __ __ ♦78 Federated Min. & Mill. 6s __ __ __ *60 Fellsmere Farms Deb. 6s, 1917 __ __ __ *97 Fellsmere Farms 1st 6s, 1925 __ __ __ *98 Ferries & Cliff House Ry. 6s, 1914 _. __ 1001/4 __ First Fed. Trust (S. F.) 5s, 1943 __ __ IOO1/2 ,__ Fitchburg & Leominster St. Ry. 1st 5s, 1917— __ __ __ 101 Fitchburg R. R. 41/38, 1914 __ „ 99 100 Ref. 41/2S, 1928 __ __ 991/2 101% 41/2S, 1933 1 __ __ __ 102 4s, 1915 __ __ 98 993/3 4s, 1916 __ __ 98 99l^ 4s, 1925 __ __ 95 96 4s, 1927 __ __ _- 96 48, 1928 >- -_ 95 96 31/3S, 1920 __ __ 931/2 __ 31/2S, 1921 _ 931/2 937/8 Flatbush Water Works Gen. 6s, 1931 .__ _- •103 Flint & Pere Marq. 6s, 1920 _„ 104 1st Cons. 5s, 1939 __ __ __ 98 Port Huron 5s, 1939 _ 95 98 4s, 1920 __ _- 92 94 Toledo Div. 5s, 1937 90 96 Fla. Cent. & Renin. 1st 5s, 1918 __ __ 10214 __ Ist Ld. Grt. 5s, 1930 __ — 1031/4 — Cons. 5s, 1943 __ __ __ 107 Fla. East Coast Ry. 1st 41/oS, 1959 „ __ __ 951^ Florida Lumber Prod. 68, 1917-22 __ >_ — 'lOO Florida Southern 1st 4s, 1945 91 92 Florida West Shore 1st 5s, 1934 _> __ 90 100 Fonda, Johns. & Gl. 1st 41/2S, 1947 __ __ 91 93 Gen. 4s, 1950 >_ __ 80 1st Cons. 41/2S, 1952 89 91 Ft. Dearborn, Saf. Vlt. & Bldg. 6s, 1917 _. — _> •102 Fort Pitt Traction 1st 5s, 1935 __ -_ 102% 105 Fort Scott Gas & Elec. 1st 5s, 1922 __ __ __ ^90 Ft. Smith Light & Trac. 5s, 1936 _ 95 Fort Smith & West 1st 4s, 1954 45 55 Fort St. Union Depot Ist 41/2S, 1941 — __ ^88 Ft. Wayne & Wab. Valley 1st 5s, 1934 __ — 78 80 Ft. Wayne Bl. & M. 1st 5s, 1935 .. _. 91 94 Ft. Wayne, Van Wert & Lima Ist 5s, 1930__ 86% 89 Fort Worth & Denver City 1st 6s, 1921 ._ 108 Ft. Worth Pow. & Lt. 58, 1931 ^97 ^98 Ft. Worth & Rio Grande 1st 4s, 1928 — ' «. 74 75% Frankford, Tacony & Hohnes. 1st 5s, 1940_._ __ ._ 95 99 Freeport Gas 1st 5s, 1932 __ __ __ ♦96 Freeport Ry., Lt. & Pr. 1st 5.^, 1922 — >_ — ^90 Fremont, Elk & Mo. Valley Ist 6s, 1933 _» _> 122 Frick (H. C.) Coke (Pit. Mon.) 1st 5s, 1915-44 — __ 4.65% Basis •Quotation nearest March 1, 1913. No quotation on that date. 1106 High Low Fries Mfg. & Power 1st 5s, 1940 Frisco Bldg. 1st 5s, 1928 __ Frisco Construe. 5% Equip., 1913-22 Frontier Telephone 1st 5s, 1922 Galesburg Ry. & Lt. 1st 5s, 1934 Galeton Eldron Water 1st Ss, 1926 Galveston Elec. Co. 1st 5s, 1940 Gal., Harris. & S. An. M. & P. 5s, 1931 Galveston-Houston Elec. 1st 5s, 3954 Gal., Houston & Hend. 5s, 1933 100 100 Gary & Interurban Ist 5s, 1930 Gas & Elec. of Bergen Co. Cons. 5s. 1949 Gas & Electric of Bergen Co. Gen. '5s, 1954 Gas Securities 6% Notes, 1914 Genl. Baking 1st 6s, 1936 95 95 5% Notes, 1915 General Elec. Deb. 5s, 1917 Deb. SVgS, 1942 5s, 1952 103% 103% Gen. Gas & Elec. 5s, 1932 General Motors 6s, 1915 General Rubber Deb. 41/28, 1915 Genessee & Wyoming 1st 5s, 1929 Georgetown Gas 5s, 1961 Georgetown & Lex. Trac. 1st 5s, 1921 Georgetown, Rowley & Ip. 5s, 1920 Ga. & Alabama 1st Cons. 5s, 1945 Georgia & Ala. Term. 1st 5s, 1948 Ga. Car. & Northorn 1st 5s, 1929 Georgia Coast & Piedmont 1st 5s, 1946 1st 5s, 1962 Georgia Elec. Lt. 1st 5s, 1930 Georgia & Flor. 1st 5s, 1956 Georgia & Fla. Term. 1st 6s, 1930 Georgia Lt., P. & Rys. 5s, 1941 Georgia Mid. 1st 3s', 1946 Georgia Pac. 1st 63, 1922 Georgia R. R. & Bkg. 68, 1922 5s, 1922 4s, 1947 Georgia Ry. & Elec. 5s, 1932 58, 1949 Ga., South. & Florida 5s, 1945 German-Amer. Copper 6s Germantown Pass. Ry 112% Gettysburg & Har. Ry. Cons. 5s, 1926 Gila Valley G. & N. W. 1st 5s, 1924 Girard Point Storage 1st 3%s, 1940 Glencoe Lime & Cement Glens Falls G. & El. Lt. 5s, 1919 Gordon, Ironsides & Fares 1st 6s, 1927 Goshen Coal 1st 6s, 1913-25 Goshen, So. Bend & Chic. Coll. 4s, 1932 Gottlieb, Bauerschmidt-Straus Brew. — 2nd Inc. 5s, 1951 1st 4s, 1951 481/2 48l^ Gouverncnr & Osgchie. 1st 5s, 1942 __ __ 108 Grand Rap. & Ind. Ext. 41/38, 1941 ^^ Muskegon Div. 5s, 1926 ♦Quotation nearest March 1, 1913. No quotation on that date. 1107 Bid Asked *89 *99 5.25% Basis 7IV2 73 __ *92 __ ♦100 90 95 104% 95 97 93% 95 100 98 99 — ♦100 " ♦97% 141 _- 82 "■" ♦94 991/8 991/2 96% 971/2 85 88 103 *6% Basis 99 1001/2 104 104% 101 103 104 __ *80 __ ♦64 100 75 ♦98 871/2 631/3 64% 109% 110% 106 110 101 90 93 1011/2 102 97 98 104 — ♦48 1031/2 1041/2 *1011/2- •1031/4 ♦84 991/4 101 ♦92 100 •100 ♦52 8 10 1021/a 85 High Low Bid Asked Grand Rap. Belding & S. 1st 58, 1924 >_ __ __ 92 Grand Rapids Edison 1st 58, 1916 _« __ — 100 Grand Rapids Gas Light 53, 1915 __ __ ^- 101 Grand Rap., Gr. Haven & H. 1st 5s, 1926 „ __ __ 90 Grand Rap. -Muskegon Pow. 5s, 1931 __ __ *98 Grand Rapids Ry. 5s, 1916 __ __ 991/2 101 Grand River Coal & Coke 1st 6s, 1919 __ „ 96 102ya Grand River Valley 4s, 1959 __ __ 93 Grand Trunk Ry. Equip. "A" & "B" 41/38, 1922 __ __ 4.70% Basis Grand Trunk &*West. 1st 4s, 1950 ( £)__ „ 90 92 Grand Trunk & West. 1st 4s, 1950 ($)._ __ 91 93 Grandin Lumber 1st 6s, 1914-25 — >_ __ *100 Grayling Lumber 1st 6s, 1913-28 — __ — 100 Grays Pt. Term. 5s, 1947 — __ 98 Great Eastern Lumber 1st 6s — — — *100 Great Eastern Timber 6s, 1917 __ » __ *99i/a Great Falls Power 1st 5s, 1940 __ __ „ 99 Great North, of Can. Con. 4s, 1934 „ __ 83 85 Gt. Northern Pow. 1st 5s, 1935 __ — — 82 Gt. Northern Ry. 41/48, 1961 ; 100 100 Great Shoshone & Twin Falls Nat. Pow. — 6% Notes, 1920-25 - '100 Great Western Power Co. 5s, 1946 — __ 8614 86% Green Bay & Western Deb. Certs. A __ __ 78 84 Green Bay & W. Deb. Income Bonds "B" 15 15 Green Bay Gas & El. Ref. 5s, 1935 _. __ *96 Greenbrier Ry. 1st 4s, 1940 ._ __ 88 911/, Greenville-Car. Pow. 1st 58, 1935 __ — — '95 Griswold Mfg. 1st 6s, 1927 — -_ — 'lOO Guanajuato Pow. & Elec. 1st 68, 1932 >_ — 93 95 Guilford -Chester Water 5s, 1939 __ — 5% Basis Gulf & Ship Island Ist & Ref. 58, 1952 __ __ 91 94 Ref. 6s, 1917 — _- — noo Gulf, Beau. & Kan. City 1st 6s, 1913 __ „ 99l^ _. 2nd 5s, 1913 __ __ 97 Gulf Term, of Mobile 1st 4s, 1957 85 90 Hackensack Water 48, 1952 __ __ 85 Hamilton & Lindenwald 1st 58, 1922 __ __ 98I/2 100 Hamilton Cataract Pow., Lt. & Tr. 1st 5s, 1943 __ „ __ "100 Hamilton El. Lt. & Cataract Pow. 1st 5s, 1929 __ — — 102 Hamilton Gas & Elec. 5s, 1935 __ __ 62 Hammond Ilium. 5s, 1926 __ __ •9514 — Hampton Cotton Mills 6s, 1916 — __ — 100 Hampton Roads Trac. 1st 41/28, 1931 — >_ — •Ql Harb. -Walker Ref. 58, 1922 — __ ♦104 Hardin-Wyandot Ltg. Ist 58, 1930 __ __ ._ •92ya Harlem Riv. & Porte. 48, 1954 _. — 951/3 96% Harriman & N. E. 1st 6s, 1916 __ __ '96 Harris Abbatoir 1st 6s „ — — MOO Harrisburg Gas 58, 1928 — __ — •103i/a Harrisburg Lt., Ht. & Pr. Ist 5s, 1924 __ __ '99% _. Harrisburg Lt. & Pr. Ist Ref. 5s, 1952 — — 93 95 Harr. Ports. Mt. J. & Lan. 1st 4s, 1913 __ >_ 99^8 — Harrison Bros. 5s, 1924 __ __ 83 85 Hartford & Conn. West 1st 41/38, 1923 __ __ 100 Hartford, Man. & Roch. 6s, 1924 __ __ 106 Hartford & Springfield 58, 1921 __ __ 92 Hartford Street Ry. 1st 4s, 1930 „ — 99 ♦Quotation nearest March 1, 1913. No quotation on that date. 1108 High Low Bid Asked Harwood Elec. 1st 5s, 1939 - - 101 103 Harwood Electric 6s, 1943 r- — — lOOVs ipoi/g Hattiesburg Trac. 6s, 1953 — — 92 _- Havana Elec. Ry. 5s, 1953 - - -- 98 Havana Tobacco 5s, 1933 — -- 63 63ya Hawaiian Com'l & Sugar 5s, 1919 — — lOlVs — Hawkinsville & Fla. Sou. R. R. 5s, 1953 — — — 94 Hayes Wheel Co. 68, 1913-17 — — — *100 Hazard Mfg. 1st 5s, 1913 - - -- JOO Hecker-Jones-Jewell 6s, 1933 — ~ lOl^A 1031/2 Hecker-Jones-Jewell Deb. 6s, 1916 — — — *98 Helena Lt. & Ry. 1st 5s, 1935 — — 89 93 Henderson Bridge 1st 6s, 1931 ~ — 105 Hercules Powder 6s, 1933 — — *97ya *99 Hereford Ry. Gen. 4s, 1930 — — 93 Hest., Manch. & Fairm. 5s, 1934 — — 103 Hilton-Dodge Lumber 1st 6s, 1914-33 — — — *100 Hoboken Ferry 5s, 1946 — — 103 Hoboken Land & Imp't 1st 5s, 1930 — — 103 105 Hocking Coal 6s, 1933 — — — *100 Hocking Valley Prod. 5s, 1961 — — 40 45 Hocking Valley Ry. — 1st Con. 41/3S, 1999 — — 991/2 101 41/3% Notes, 1913 — — *99% *99y8 HoUiston Water 1st 5s, 1930 — — — 100 Holly Mfg. 1st 5s, 1933 — — — *89y, Holton Power 1st & Ref. 6s, 1943-49 — — 61/3% basis Home Telephone 5s, 1933 — — 85% 86y2 Home Telephone 1st Ref. 5s, 1945 — — 791/3 791/2 Home Telephone of Hlinois 5s, 1936 __ — — *87 Home T. & T. (Los Ang.) 1st & Ref. 5s, 1945 __ __ *78i/2 *80i/8 Home Tel. & Tel. of S. D. 5s, 1934 __ „ — 631/^ Honesdale Cons. Lt., Ht. & Pow. 1st 5s, 1938— — __ — 100 Honolulu R. T. & L. Co. 6s, 1937 __ — 106 Hoopeston Gas & Elec. Ist 5s, 1936 — — — *83 Hoosac Tunnel & Wilm. 1st 5s, 1933 __ — 80 Hoosick Falls Elec. 5s, 1930 __ __ — 100 Hoster-Col. Brew. 6s, 1940 *66l^ __ Hoster-Columbus Brew. 6s, 1955 __ „ 65 6614 Hot Springs Water __ __ __ 99 Houghton Co. Elec. Lt. 1st 5s, 1937 __ __ __ 96 Houghton Co. Gas & Coke 5s, 1931 __ __ __ *90 Houghton Co. Street Ry. 5s, 1930 __ __ 96 981/, Houghton Co. Trac. 1st 58, 1937 __ __ 93 94 Housatonic Power 41/33, 1914 __ __ __ 99% Housatonic R. R. 5s, 1937 _» __ 110 Houston Belt & Term. 1st 5s, 1937 __ __ 991/2 100 Houston East & West Texas 1st 5s, 1933 __ __ 103 Houston Electric 5s, 1935 __ __ 99 100 Houston Gas 1st 5s, 1930 __ __ __ ♦lOO Houston Lighting & Power 5s, 1931 *97i4 __ Houston Oil 6s, 1935 __ __ __ *82 Houston & Texas Cen. 1st 5s, 1937 __ __ IO914 109% Houston & Texas Cen. Gen'l 4s, 1931 __ __ 93 94 Houston, T. C, Waco & N. W. 6s, 1930 __ __ 114 118 Huasteca Pipe Line 6s, 1939 __ 75 80 Hudson Coal Co. 4s, 1917 __ __ 90 Hudson Companies 6s Notes, 1913 __ __ 98l^ _« Hudson County Gas 5s, 1949 __ __ 103^^ "Quotation nearest March 1, 1913. No quotation on that date. 1109 High Low Bid Asked Hudson & Manhattan 41/28, 1957 "64 *65 Hudson Navigation 6s, 1938 — — 90 93 Hudson River Gas & Elec. 1st 5s, 1929 — — 95 100 Huebuer-Toledo Brew. 6s, 1930 — — 69 71 Hunter Canal 6s, 1933 *90 Huntingdon & B. Top. 1st 4s, 1920 — — 91 93 Huntingdon & B. Top. 2d 4s, 1925 — — 85 Huntingdon & B. Top. Cons. 6s, 1925 — — 91 93 Huntingdon & Broad Top 1st 6s, 1922 — — 104 Huntington & Big Sandy 1st 6s, 1922 — — *104 Huron Light & Power 1st 6s, 1932 — — ~ *100 Hutchinson & Southern 1st 5s, 1928 — — 103 106 Hutchinson Water, Light & Gas 5s, 1935 __ — *80 Hutchinson Water, Light & Power 1st 48, 1928 _. — *74 Hydraulic Power 1st Ref. 5s, 1950 — — — *103i/2 Hydraulic Pressed Brick 5s, 1913-22 — — — *100 Idaho Irrigation Co. 6s, 1912-21 ~ — — *60 Idaho-Oregon Lt. & Pr. 1st Ref. 6s, 1925-40— — — 92 951/2 Idaho-Oregon Lt. & Pr. 1st Ref. 6s, 1940 — — "70 Idaho & Washington Northern 1st 5s, 1932— — ~ — 96 Illinois Athletic Club 51/38, 1926 — — — *9iy2 Illinois Central R. R. — Cairo Bridge 4s, 1950 — — 92 94 Middle Div. 5s, 1921 — — *102 St. Louis Div. Sy^s, 1951 — — — 85 Springfield Div. 31/2S, 1951 — ~ 80 Deb. 5s, 1913 — — 100 West. Lines 4s, 1951 — ,— 94 961/2 St. Louis & Term. 3s, 1951 (Coupon) __ _. — 77 St. Louis & Term. 38, 1951 (Regular) __ — ~ 73 Deb. 41/2S, 1940 — — — 88 41/38, 1914 — — 99 99% Equip. 41/2S, 1922 — — 4.60% basis Equip. 41/28, 1913-23 — — 4.62% basis Ist 4s, 1951 — — 1021A __ 1st 31/2S, 1951 -_ — 88I/2 — Coll. 4s, 1952 _- — — 961/a Ref. 4s, 1955 __ „ 94l^ 96 Pur. Lines 31/2S, 1952 __ ._ — 83i/a L. N. 0. & T. 4s, 1953 „ __ 95 971/2 Litchfield Div. 3s, 1951 __ __ __ 751/3 Louis. Term. 31/2S, 1953 __ __ __ 84 Omaha Div. 3s, 1951 __ __ __ 69% niinois Central Trac. Ist 5s, 1933 — „ *93i/2 — Illinois Northern Util. 1st Ref. 5s, 1957 — — 931/2 95 Illinois Steel Deb. 5s, 1913 __ __ 100 Illinois Steel Deb. 41/08, 1940 __ __ __ 88 Illinois Stone 6% Notes, 1917 — __ __ *100 Illinois Valley 1st 58, 1935 __ __ 96 100 Independent Brew. 6s, 1955 __ __ 82% __ Independent Brew. 6s, 1937 __ __ __ *44 Independent Elec. 1st 6s, 1932 __ __ *100 Indian Refining 1st 6s, 1912-21 __ __ __ *100% Indiana, Bloomington & Western 1st 4s, 1940 __ __ *90 Indiana, Colo. & East. 5s, 1926 __ __ 88 90 Indiana Co. 1st 5s, 1950 __ 97 Indiana, Decatur & Western Ry. 5s, 1935 __ __ *102 *105 Indiana, Illinois & Iowa 1st 4s, 1950 _. __ 91 94% •Quotation nearest March 1, 1913. No quotation on that date. 1110 High Low Bid Asked Indiana Lighting 4s, 1958 — — 68 70 Indiana & Mich. Elec. 1st 5s, 1957 — — *93 Indiana Nat. Gas & Oil 5s, 1936 ~ — — 89^8 Indiana Nor. 1st 5s, 1933 — — 78 80 Indiana Rya. & Lt. 1st & Ref. 5s, 1943 — — — 94 Indiana Steel 5s, 1952 lOOi/g lOOi/g Indiana Union Trac. 1st 5s, 1933 — — 83 84 Indiana Union Trac. Ist 4y2S, 1926 — — 90 100 Indianapolis Canal Club Prop. 1st 6s, 1917-23 — — *5%% basis Indpls. Dec. & West. 5s, 1935 — — 102 105 Indpls. Dec. & West. guar. 5s, 1935 __ — 100 105 Indianapolis & Eastern 5s, 1927 — — 102 103 Indpls. Gas 1st Cons. 5s, 1952 — — 87 90 Indianapolis & Green. Rap. T. 1st 5s, 1929 — — — 101 Indpls. Lt. & Heat, Cons. 5s, 1940 __ — 991/2 __ Indianapolis Light & Pr. 1st Os, 1922 — — "lOl^ ~ Indianapolis & Louisville 1st 4s, 1956 — — — 84 Indianapolis & Martinsville R. T. 1st 5s, 1932 „ __ 91 97 Indianapolis Northern Ry. 5s, 1932 __ — 82 84 Indianapolis & Northwest. Tr. 1st 5s, 1923 __ __ 92 94 Indianapolis & St. Louis 1st 7s, 1919 — — 110 Indpls. Shelbyv. & Southeast 5s, 1919 >_ __ __ *100 Indpls. Shelbyv. & Southeast 1st 5s, 1932 __ __ 94 101 Indianapolis & Southeast. Trac. 1st 5s, 1935. __ — 82% 87 Indianapolis Street Ry. 4s, 1933 __ __ 82% 84 Indpls. Trac. & Term. 1st 5s, 1933 981/2 100 Indianapolis Union Ry. 41/28, 1926 «_ __ *96 *100 Indianapolis Water 5s, 1926 __ __ 100 100% Indianapolis Water 1st Ref. 41/3S, 1940 __ __ 9I1/2 931/3 Indianapolis Water Works Secur. 6s, 1948 __ __ -_ *100y2 Ingersoll-Rand 5s, 1935 __ __ 100 Inland Steel 1st 6s, 1911-28 __ __ __ 'loe Inland Steel Ext. & Ref. 6s, 1942 _. __ __ *102i/2 Inspiration Cons. Copper 1st 6«, 1922 100 103 Inst, for Encouragement of Irr. Wks. & Dev. of Agric. 41/2S, 1943 .. __ __ 95 Insurance Exch. Bldg. 5s, 1925 *99% Insurance Exch. Bldg. 2nd 6s, 1915 __ — __ *95% Interborough-Met. Col. Trust 41/2S, 1956 79% 791/2 Interborough Rap. Tran. 5s, 1952 __ __ 103% 103l^ Interborough Rap. Tr. 1st & Ref. 5s, 1956 __ — __ IO3V2 Intermtn. Ry., Lt. & P. 1st 6s, 1942 __ -_ _- 97y2 Int'l. Agric. Corp. Coll. 5s, 1952 __ » 93 95 Intemt'l. & Gt. Northern 1st 6s, 1919 __ __ 106% 107 Internt'l. & Gt. Northern 6% Notes, 1914 _- __ 98l^ 98% Int'l. Harvester 5% Notes, 1915 __ _« 100 100% Inter. Merc. Marine 41/2S, 1922 ._ __ 63V2 64 Inter. Navigation 58, 1929 __ 791^^ Int'l. Paper 6s, 1918 __ __ 103% 104 Int'l. Paper Conv. 5s, 1935 ._ >_ 88I/2 89 Internat. Ry. ref. & imp. 5s, 1962 __ 971A Int'l. Salt 5s, 1951 __ __ 61 53 Int'l. Silver 6s, 1948 __ __ no Int'l. Steam Pump 5s, 1929 __ __ 84l^ 89 Int'l. Traction 4s, 1949 69 69V2 Interstate Indep. Tel. & Tel. 5s, 1927 __ __ >_ ♦57 Interstate Rys. 4s, 1943 __ __ 59 60 Interstate Telep. 1st 5s, 1921 __ _« *46 •48 Intenirban Ry. (Des Moines) 1st 5s, 1921 __ «» _« •95 •Quotation nearest March 1, 1913. No quotation on that date, ; 1111 High Low Bid Asked Intenirban Ry. & Term. 58, 1928 Intenirban Ry. & Term. 1st 5s, 1943 Iowa Central 1st 5s, 1938 Iowa Central 1st & Ref. 4s, 1951 Iowa Falls & S. C. 1st 7s, 1917 Iowa., Minn. & N. W. 1st SVgS, 1935 Iowa-Nebraska Public Serv. 1st 6s, 1931 Iowa Ry. & Lt. 1st & Ref. 5s, 1933 Iron Mtn. Lt. & Fuel 58, 1937 Iroquois Iron deb. 6s, 1917 Ithaca- Cortland Trac. 5s Jackson & Battle Cr. 5s, 1923 Jackson Cons. Trac. 5s, 1934 Jackson Gas 5s, 1937 Jack., Lans. & Sag. 1st 31/38, 1951 Jackson Lt. & Trac. 1st 58, 1922 Jacksonville Electric 5s, 1927 Jacksonville Ferry & Land 1st 6s, 1937 Jacksonville Gas 1st 5s, 1942 Jacksonville Gas deb. 68, 1922 Jacksonville Ry. & Lt. 1st 5s, 1931 Jacksonville Term. 1st 5s, 1939 Jacksonville Trac. 1st 5s, 1931 Jamaica & B'klyn 1st 5s, 1930 Jamaica Water Supply Ist 5s, 1928 Jamaica Water Supply 5s, 1954 Jamestown Fr. & Clearfield 1st 43, 1959 Jamestown St. Ry. 1st 68, 1923 Jamison Coal & Coke 1st 58, 1930 Jamison Coal & Coke 1st 5s, 1931 Jeff. City L., H. & P. Ist 5s, 1925 Jeff. & Clearf. Coal & Iron 2nd 5s, 1926 Jeff. & Clearf. Coal & Iron 5s, 1926 Jefferson R. R. 5s, 1919 Jenkintown & Cheltenham Gas Ist & ref. 5s, 1933 Jersey Central Trac. 1st 5s, 1931 Jersey Central Trac. Ref. 5s, 1954 Jersey City, Hob. & Paterson 4s, 1949 Jewett City Water 1st 5s, 1915 Johnson Co. (Pa.) 1st 6s, 1914 Johnstown (Pa.) Pass. Ry. Ref. 4s, 1931 Joliet, Economy Lt. & Water 5s, 1956 Joliet & North. Ind. 1st 4s, 1957 Jones & Laughlin Steel 5s, 1939 Joplin Home Telep. Cons. 5s, 1925 Joplin «& Pittsburgh 1st Ss, 1930 Joplin Union Station 1st 41/28, 1940 Kal. Allegan & G. R. 1st 5s, 1938 Kalamazoo & White Pigeon 5s, 1940 Kaministiquia Pow. 1st 58, 1937 Kanawha & Michigan 4s, 1990 Kanawha & Hock. Coal & Coke 5s, 1951 Kanawha & Michigan 2nd 5s, 1927 Kana. & Mich. Eq. 41/38, 1913 Kana. & Mich., St. Mary's Div. 4s, 1951 Kanawha & W. Va. 1st 5s, 1955 ♦Quotation nearest March 1, 1913. No quotation on that date. 1112 100 100 97% 98 59 60 1071/2 109 86 *90 *99 951/2 971/2 99 *98%, ~ *75 98 100 96 100 97 100 85 87 94 97 97 99 *10 94 96 1 100 93 95 951/2 971/2 100 __ *94i/2 *95 93 103 __ ♦93 ■• *100 951/4 99 95 __ 101 __ 100 — •991/2 96 100 85 92 80 8O1/2 5% basis 1031/2 85 88 ^ •^100 85 88 1001/4 10034 86 96 98 90 — 104 113 ' •1151/2 104 911/2 951/2 97y4 971/2 98y2 51/4% 4%% 87 90 — 87% High Low Bid Asked Kankakee Gas & Elee. 1st ref. os, 1930 — — 961/2 98ya Kankakee & S. W. 5s, 1921 .- — — 101 Kan. City Belt Ut 6s, 1916 — — IO31/2 104^4 Kan. City Brew. 6s, 1930 *75 Kan. City. Clin. & Springf. 5s, 1925 — — 92 96 Kansas City Elev. By. 4s, 1922 — — 75 80 Kansas City Elev. By. 6s, 1922 — — 102 Kan. City, Ft. S. & Memp. Cons. 6s, 1928 __ — lHVg 1121/2 Kan. City, Ft. S. & Memp. Ref. 48, 1936 — — 76 77 Kan. City, Fort S. & Memp. Eq. 41/2S, 1915 — — — 99^/8 Kan. City Gas 1st 53, 1922 — — — 94 Kansas City Home Teleph. 5s, 1923 — — 921/2 931/2 Kansas City Home Teleph. 5s, 1923 — — 921/2 93i/g Kansas City Long Dist. Tel. 5s, 1925 — — 90% 92 Kan. City, Mem. & Birm. 4s, 1934 — — — 93 Kan. City, Mem. & Birm. Inc. 5s, 1934 „ __ — 83 Kan. City & Mem. By. & Bridge 1st 5s, 1929__ — _. — IOI14 Kan. City, Mex. & Orient 1st 4s, 1951 — — 25 33 Kan. City & N. W. Ist 5s, 1933 — — 96 100 Kansas City & Pacific 1st 4s, 1990 — — 86 Kansas City By. & Lt. 5s, 1913 __ — 89 90 Kansas City By. & Lt. 6s Notes, 1912 — __ 831/3 911/2 Kansas City, Southern By. — Bef. 5s, 1950 971/2 971/2 Equip. "D" 5s, 1913-24 __ _. — 100 1st 3s, 1950 — -_ — 71% 1st 3s, 1950 -- — — 71% Kansas City Stk. Yds. conv. 5s, 1913 __ — *99i/2*100 Kan. City Terminal 1st 4s, 1960 __ __ 93% 94 K. C. Viad. & Term. 41/28,1934 . __ __ 44 50 Kansas City- Western 1st 5s, 1925 __ __ 82 85 Kansas City & Westport Belt 5s, 1926 __ __ 90 91 Kansas & Colo. Pac. Ist ref. 6s, 1938 __ __ __ *105i4 Kan. Gas & Elec. 1st 5s, 1922 __ __ 95 98 Kansas & Missouri 1st 5s, 1961 __ __ 86 93 Kansas Natural Gas 6s, 1916 __ __ 93 98 Kansas Natural Gas 2nd 6s, 1918 __ __ 65 70 Karpen Bldg. (Chic.) 1st 5s, 1913-25 __ __ __ *99i/2 Keene Gas & El. 1st 5s, 1935 __ __ __ 102 Kennebunk El. Lt. 1st 5s, 1930 __ _. __ 100 Kentucky Central 4s, 1987 __ __ 90% 91 Kentucky Elec. 1st 5s, 1926 __ _« ._ *98 Kent. Pub. Serv. 1st & Bef. 6s, 1922 __ __ __ 100 Kentucky Solvay Coke 1st 6s, 1915-20 __ __ __ *100 Kentucky Trac. & Term. 1st 5s, 1951 __ __ 89 94 Keokee Consol. Coke 1st Bef. 5s, 1959 __ __ *84 Keokuk & Des Moines 1st 5s, 1923 __ _> 97 100 Key West Elec. 1st 5s, 1956 __ __ *5.60% basis Key West Gas 1st 63, 1931 __ __ __ 96 Keystone Coal & Coke 1st 6s, 1912-31 __ __ __ *102% Keystone Telep. 1st 53, 1935 __ __ 391/2 90 Kings Co. El. Lt. & P. 1st 5s, 1937 __ __ __ 103i/a Kings Co. E. L. & P. Pur. M. 6s, 1997 __ __ 1121/4 114% Kings Co. E. L. & P. Conv. 6s, 1925 __ __ 120 123 Kings Co. E. L. & P. Deb. 6s, 1922 __ __ 120 123 Kings Co. Elevated 1st 4s, 1949 __ __ 83l^ __ Kings Co. Gas & Hlum. 1st 58, 1940 __ __ 95 100 Kings Co. Ltg. 1st Ref. 5s, 1954 __ __ 98 100 Kingston Gas & Elec. 1st 58, 1952 __ __ __ 96i/J •Quotation nearest March 1, 1913. No quotation on that date. 1113 High Low Kinloch Long Dist. Tel. 1st Ss, 1929 Kinloch Telephone 6s, 1928 Kirby Lumber 6% cert., 1914-16 Kirby Lumber 6% cert., 1923 Klots Throwing 1st 6s, 1939 .__- Kneeland-McLurg Lumber 1st 6s, 1923 Knickerbocker Ice 1st 5s, 1941 Knickerbocker Ice 1st 5s, 1928 Knox. & Cine, lat 4s, 1920 Knoxville Gas 1st 5s, 1933 Knoxville & Ohio 1st 63, 1925 Knoxville Ry. & Lt. 5s, 1945 *100% „ Knoxville Ry. & Lt. 5s, 1946 Knoxville Trac. 5s, 1938 Kokomo Marion & W. Trac. 1st 5s, 1933 La Belle Iron Works 68, 1923 Lackawanna Coal & Lumber cons. 6s, 1961 Lackawanna Steel 5s, 1915 Lackawanna Steel 5s, 1923 Lackawanna Steel 5s, 1950 Lackawanna Tel Ist 5s, 1930 Lackawanna & Wyo. Val R .T. 58, 1951 Laclede Gas Lt. 1st 5s, 1919 Laclede Gas Lt. Ref. & Ex. 53, 1934 La Crosse Gas & Elec. 5s, 1921 La Crosse G. & E. ref. 51/28, 1931 Lafayette & Logansport Ist 5s, 1936 Lake Erie & Det. Riv. 1st 41/2S, 1932 Lake Erie & West'n 1st 5s, 1937 Lake Erie & West'n 2nd 5s, 1941 Lake Gas (Chic.) 1st 6s, 1915 Lake Roland Elev. 1st 5s, 1942 107 107 Lake Shore Elec. Cons. 5s, 1923 *9434 __ Lake Shore Elec. Gen. 5s, 1933 __ __ 83 83% Lake Shore & Michigan Southern Ry. — 31/38, 1997 Deb. 4s, 1928 91 91 4s, 1931 91 90% Coll. Tr. 31/38, 1998 Lake St. Elevated 1st 5s, 1928 Lake Superior Corp. 5s, 1924 Lake Superior Corp. Coll. 5s, 1944 Lake Tahoe Ry. & T. Co. 5s, 1931 Lansing Fuel & Gas 5s, 1921 La Porte & Mich. City Trac. 1st 5s, 1930 Laramie, H. P. & Pac. ref. 6s, 1932 La Salle Hotel 6s, 1915-25 Latrobe-Connels. Coal & Coke 1st 6s, 1931— Latrobe Water gen. 5s, 1932 Laurentide Paper 1st 68, 1920__ Leadville Lt. & Pow. 1st 6s, 1924 Leavenw. Lt. H. & P. 1st 5s, 1923 Leavenw. Term. Ry. & Edge. 1st 5s, 1923 Leggett (F. H.) Co. 1st 6s, 1922 Lehigh Coal & Navig. 41/3S, 1921 Lehigh Coal & Navig. 41/2S, 1914 Lehigh Coal & Navig. R. R. 4s, 1914 Lehigh Coal & Navig. Ext. 4s, 1914 *Quotatlon nearest March 1, 1913. No quotation on that date. 1114 Bid Asked 911/4 913/4 1041/2 1051/2 •991/4 981/2 98 100 __ ♦100 85 87 •843/4 94 90 95 113 1131/2 911/2 104 105% 97 100 1021/2 1031/2 __ •66 94 95 93 97 75 781/2 70 80 85 90 102 10234 100 1011/2 100 •971/2 •84 85 92 104 1031/2 — '' *102i/2 ~ 88I/2 771/4 773/4 88 741/4 90 741/2 95 97 96 97 •86I/2 •70 •991/2 100 101 971/2 100 107 __ •80 92 96 80 •99 __ 102 100 971/2 97 ~ High LfOW Bid Asked Lehigh Coal & Navig. Gen. 41/28, 1924 — — 103 :.- Lehigh Coal & Navig. 4s, 1948 ^ - - 96 .- LehiSh Coal & Navig. Coll. Tr. 41/33, 1930 — - - 103 102% Lehigh & Hud. River 2nd 5s, 1917 — — 100 Lehigh & Hud. Riv. Gen. 5s, 1920 — — 102 Lehigh & Lake Erie 1st 41/28, 1957 — — 100 105 Lehigh & New Eng. 1st 5s, 1945 — — IO41/2 IO6I/2 Lehigh & N. Y. 1st 4s, 1945 ~ — — 94 Leh. Val. Coal 5s, 1933 IO51/2 IO51/2 Leh. Val. Coal 4s, 1933 — — 94 96 Lehigh Valley of N. Y. 1st 41/2S, 1940 — — 101 i/a 1033/^ Lehigh Valley R. R.— 1st Ex. 4s, 1948 - - 101 103 Col. T. 4s, 1926 — ~ 4.50% 4.30% Irredeemable 41/2S, — — *111 *lliy3 Irredeemable 6s — — — *144 Cox Bros, serial 4s, 1926 — — *4i/2% basis Cons. 6s, 1923 — — 114 41/2S, 1923 — — — 103% 4s, 2003 - - 951/2 95% Term. Ry. 5s, 1941 — — HOVs — Lehigh Valley Term. 1st 5s, 1941 — — •I10i/8*112 Lehigh Valley Transit 1st 5s, 1935 — — 102^/8 1031/3 Lehigh Valley Transit 1st 4s, 1935 — — 871/2 88 Lehigh Valley Transit Cons. 4s, 1935 __ — 76 79 Lehigh Valley Transit Ref. 5s, 1960 _- — 901/2 93 Lehigh & Wilkesb. Coal Con. 4s, 1915-35 — __ 4.40% 414% Lenawee Co., Gas & Elee. 51/2S, 1927 — — — *100 Leominster, Shirley & Ayer St. Ry. 1st 5s, 1921 — — — 102 LeRoy & Caney Valley A. L. 1st 5s, 1926 — — *98 Lewiston & Auburn Elec. 1st 5s, 1939 __ -_ *97 Lewiston, Augusta & Waterville St. Ry. 5% Notes, 1913 _- — — *100 Lexington & Boston St. Ry. 1st 41/2S, 1920 — — — 96 Lewiston, Bruns. & Bath 1st 5s, 1918 __ __ 95 100 Lex. Ave. & Pav. Ferry 5s, 1993 — — 100 Lewiston & Clarkston Imp't. 6s, 1925 __ „ __ *93% Lexing. Hydr. & Mfg. 1st 5s, 1936 __ __ — 96 Lexington Ry. 1st 5s, 1949 __ __ 94 95 Liggett & Myers Tob. 7s, 1944 __ __ 121 121% Liggett & Myers Tob. 5s, 1951 __ ._ 981/2 99 Lima Electric 1st 5s, 1916 __ __ 98 100 Lima Electric 2nd Cons. 5s, 1925 __ __ 96 97l^ Lima Locomotive 1st 63, 1932 __ 98 101 Lincoln Gas & El. Lt. 1st 5s, 1941 __ __ 85 90 Lincoln Telephone 6s, 1923 ,- __ __ *95i/2*100 Lindell Ry. 1st 41/2S, 1921 __ _. 97% _- Lindsay Water 1st 5s, 1919 __ __ *80 Litchfield & Mad. 1st 5s, 1934 __ __ 87 95 Little Miami 5s, 1962 __ __ 96% 97 Little Rock Bridge Ist 6s, 1919 __ ._ __ *105 Little Rock Gas & Elec. Ref. 6s, 1937 — „ »_ *100 Little Rock & Hot Spgs. West. 1st 4s, 1939__ __ __ 82% ~ Little Rock, June. 1st 6s, 1916 __ __ 99 Little Rock Ry. & Elec. 5s, 1933 __ __ __ 105l^ Little Rock Ry. & Elec. 6s, 1938 *107i/4 — Lockport & Olcott Ist 5s, 1920 __ __ __ 97 Lockport Gas & Elec. 1st 5s, 1920 -. >_ 96 100 'Quotation nearest March 1, 1913. No quotation on that date. 1115 High Low Bid Asked Lockport Lt., H. & P. Ist 6s, 1938 - - 91 95 Locomobile Co. of Amer. 1st 6s, 1922 — — — *99 Locomotive Machine Co. 1st 4s, 1924 __ __ *86 London & Jefferson Bridge gtd. 4s, 1945 — — SS^^ — Lone Star Gas 1st 6s, 1919 — — — 97 Long Beach Co. 1st 68, 1935 — — •1221/2 _- Long Beach Cons. Gas. 6s, 1935 — — 10054 __ Long Beach (Estates of) 6s, 1917 — — — *76 Long Bell Lumber Ist ref. 6s, 1911-22 — — *99 Long Dock Co. Cons. 6s, 1935 — — 122% ~ Long Island C. & F. Con. 5s, 1937 — — 101 Long Isld. Ltg. Ist 5s, 1936 — — 931/2 95 Long Island R. R. — Unified 4s, 1949 — — 89 90 2nd 7s, 1918 — — 108 Deb. 5s, 1934 — — — 103 Montauk Ex. 5s, 1945 — — 101 North Shore Br. 1st 5s, 1932 __ — 103 1st Con. 5s, 1931 — — — 110 1st Con. 4s, 1931 _> __ 90 Gen'l. 4s, 1938 - _- — 91% — Ferry 41/38, 1922 — — __ 100 R. R. 4s, 1932 89 90 Ref. 4s, 1949 „ __ 94% 951/2 Lorain & Cleve. Ry. 5s, 1927 "99% __ Lorain St. Ry. cons. 5s, 1949 __ __ __ *95 ' Lorillard Co. (P.) 7s, 1944 __ -_ 120% 1211/, Lorillard Co. (P.) 5s, 1951 __ __ 981/2 99 Los Angeles Elec. 5s, 1928 .._ __ 100 Los Angeles Gas & Elec. 5s, 1934 _. __ 99% __ Los Ang. Gas & El. 1st & ReL 58, 1939 __ __ 971/2 981/, Los Angeles Light'g G'd. 5s, 1924 __ __ 100 L. A. Pac. R. R. 1st Con. Mtg. 5s, 1931 __ __ IO31/2 104 Los Angeles Pacific 1st 4s, 1950 __ __ 84 86% Los Ang. Pac. R. R. of Cal. 5s, 1943 __ __ 99 L. A. Pac. R. R. of Cal. 5s, 1946 __ __ 99 Los Angeles & Pasadena Elec. Ry. 1st 5s, 1928 __ __ *102 *104 Los Angeles Ry. 5s, 1938 __ __ 105 Los Angeles Ry. 5s, 1940 __ __ 96l^ __ Los Angeles Traction 5s, 1938 106 Louisiana & Arkansas 1st Ss, 1927 __ __ 93 941/3 Louisiana Western 1st 6s, 1921 __ 106 Louisville Lighting 1st 5s, 1953 __ __ *92% Louis., Cine. & Lex. 41/38, 1931 __ __ 102 104 Louisv., Henderson & St. L. 1st 58, 1946 __ __ 106 107 Louisville Home Teleph. 1st 5s, 1922 __ __ 89Vi Louisville & Jeff. Bridge 4s, 1945 __ __ 85% Louisville & Nashville R. R, — Atl., Knox & Cine. 4s, 1955 92 92 Mob. & Montg'y. 41/2S, 1945 __ __ 102% 103% South Mon. Jt. 4s, 1952 __ 89% Pens. & Atl. 1st 6s, 1921 __ __ loo St. Louis Prop. 1st 5s, 1916 *98 St. L. S. E. 6s, 1921 ._ „ •log •112% Genl. 6s, 1930 112 Genl. 5s, 1937 __ __ m ~~ Unified 4s, 1940 96% 971/, Col. Tr. 5s, 1931 . loes/I E. H. & Nash. 1st 6s, 1919 110% 1111/ N. O. & Mobile Ist 6s, 1930 II7 120U N. 0. & Mobile 2nd 6i, 1930 _ 114^ 1116 High Low Bid Asked Pad. & Memp. Div. 6s, 1920 — — 105% __ Pad. & Memp. Div. 4s, 1946 — — *90 St. Louis 1st 6s, 1921 — — ~ H^Vg St. Louis 2nd 3s, 1980 — — — WVa Louisv. & Nor. Ry. & Ltg. 1st 5s, 1925 — — — 75 Louisville Ry. Cons. 6s, 1930 — — .104% IO51/3 Louisville Ry. 2nd 4y3S, 1940 — — 95% 96% Louisville Ry. Genl. 5s, 1950 — — IOO3/4 101 Louisville & South Ind. Trac. 1st 5s, 1923—— — — — *65 Louisville Water 4s, 1946 — — 100 102 Louisville Water 4s, 1950 — ~ 100 102 Lowell Elec. Light. 1st 5s, 1914 — — 100 Lowell Law. & Hav. 1st 5s, 1923 — — 102 105 Luzerne Co. Gas & El. 1st Ref. & Imp. 5s, 1948 — __ 971/2 99 Lynch. Trac. & Lt. Cons. 5s, 1931 — — — 95 Lynch. Trac. & Lt. 1st 5s, 1931 — — — 97 Lynn & Boston 1st 5s, 1924 — — 102 104 Lynn & Boston 6% Notes, 1917 — — — *104% Macon, Dublin & Sav. 1st 58, 1947 — — 98 991/3 Macon Ry. & Lt. 1st Cons. 5s, 1953 __ — — 99 Madison Gas & El. 1st 6s, 1926 — — 103 109 Madison Interurban Trac. 1st 5s, 1931 — — — *97 Madison River Pr. 1st 5s, 1935 — — 95 97i/a Mahoning & Shenaugo Ry. & L. 1st 5s, 1916— __ — 971/2 98 Mahoning Coal R. R. l»t 5t, 1934 __ — 109 lioy, Maine Central R. R. Col. 5s, 1923 — — 103 "A" 41/2S, 1916 ~ — — *99i/s «B" 41/2S, 1917 — — — *100 4% Notes, 1914 — — — 99 Maine & New Brims. El. Pow. 6% perp. deb— __ — — 104 Mallory S. S. 1st 5s, 1932 „ __ 84 88 Manchester & Law. 4s, 1922 — — — 98% Manchester (N. H.) Tr. L. & P. 1st, 5s, 1921 — — 100 Mangum Elec. 1st 5s, 1946 __ — — *93 Manhattan Ry. Cons. 4s, 1990 — __ 93% 95 Manila Elec. 5s, 1953 __ __ 96 971/2 Manilla R. R. (South Lines) 1st 4s, 1936 — ._ __ *86 Manilla Suburban Rys. 1st 5s, 1946 — — 85 871/2 Manistee & N. E. 1st 5s, 1912-39 __ __ *85i/3 „ Manitoba & Southeastern, lat 4s, 1929 ( £)— __ __ 981/2 100 Manitoba S. W. Colonization 5s, 1934 __ __ 101 Manitowoc, Gr. Bay & West 1st SVgS, 1941 __ __ 841/2 __ Mankato Gas & Elec. Lt. 1st 5s, 1920 __ __ 96 IO21/2 Mankato Gas & Elec. Lt. Cons. & Ref. 5s, 1935 __ __ __ 100 Manufacturers Co. 5% Notes, 1916 __ __ __ *98% Manufacturers Lt. & Ht. 1st 6s, 1915 __ __ *102 Manufacturers Water 1st 5s, 1939 __ __ 102% Marietta Elec. 6s, 1917 __ — __ ♦103 Marin Water & Power 5s 99% Market St. El. Pass. Ry. 4s, 1955 __ __ 96% 96% Mkt. St. Ry. 1st Con. Mtg. 5s, 1924 __ __ _. 93 Marquette Co. G. & E. 1st 6s, 1930 __ __ __ *100 Marq. Houghton & Ont. 6s, 1925 __ __ 111 113% Marshfield & So. East. 1st 4s, 1951 __ _> 87 90 Maryland Coal & Coke 6% Notes, 1915 __ __ __ *98% Maryland, Del. & Va. 5s, 1955 __ __ 95 98 Maryland Electric Rys. 1st 5s, 1931 97% 97% •Quotation nearest March 1, 1913. No quotation on that date. 1117 High Low Maryland & Pa. 1st 4s, 1951 Income, 4s, 1951 Maryland Steel 1st 5s, 1922 Mason City & Clear Lake Trae. Ref. 68, 1932 Mason City & Ft. Dodge 1st 4s, 1955 Masonic Hall & Asylum Fund Trustees of N. Y Mass. Co. Coll. 5s, 1937 Mass. Elec. 41/2% Notes, 1913 Mass. Gas 41/2S, 1929 Mass. Gas 41/28, 1931 McGregor & Mclntyre, Ltd., 6s, 1927 McKeesp. & Belle V. 1st 6s, 1918 McM., M., W. & Al. 1st 6s, 1917 Meadow Brook Water 1st 5s, 1947 Mechanical Rubber 6s, 1918 Memphis Lt. & Pr. Ref. 5s, 1931 Memphis St. Ry. 5s, 1945 Memphis Union Station Col. Notes 5s, 1913 — Merchants Bridge 6s, 1919 Merch. Despatch Transp. Equip. 41/285 1913-26 Merch. Elec. Lt. & Pw. 5s, 1929 *97y3 — Merchants Heat & Lt. Ref. 5s, 1922 Merchants Power (Mem.) 1st 5s, 1940 Merchants Refrigerating 1st 6s, 1917-31 Meriden Horse R. R. Genl. 5s, 1924 Meriden Terminal 1st 4s, 1955 Meridian Lt. & Ry. 58, 1944 Merion & Radnor Gas & Elec. 1st 5s, 1954 Metropolitan Corrigan 5s, 1916 Metropolitan Elec. Ist 5s, 1939 Metropolitan Elevated 1st 4s, 1938 Metropolitan Gas 1st 5s, 1941 Metropolitan R. R. 5s, 1925 Metropolitan St. Ry. Ref. 4s, 2002 Metropolitan Street Ry. 5s, 1913 Metrop'n Tel. & Tel. 5s, 1918 Met. West Side Eler. 1st 4s, 1938 Met. West Side 'ev. Ext. 4s, 1938 Mexican Cent. Eq. & Col. 5s, 1917 Mexican Cent. 2nd Ser. 5s, 1919 Mexican Coal & Coke 5s, 1926 Mexican Elec. Lt. 1st 5s, 1935 Mexican International P. L. ^V^s, 1947 Mexican International 1st 4s, 1977 Mexican Lt. & Pow. 1st 53, 1933 Mexican Mahogony & Rubber 6s, 1931 Mexican Nat. Gas bonds Mexican Nat'l Packing 1st 6s, 1931 Mexican Northern 1st 6s, 1930 Mexican Petrol. 6s, 1921 Miamisburg & Germantown 5s„ 1922 Mich. Air Line Ist 4s, 1940 Michigan Central R. R. — 5s, 1931 (Coup.) 1st 3ypS, 1952 5s, 1931 (Reg.) (Det. & Bay City) 1st 5s, 1931 41/3% Notes, 1914 •Quotation nearest March 1, 1913. No quotation on that date. 1118 Bid . Asked 871/3 68 68I/3 99 100 ♦101 * ^105 65 70 ♦102 *104 91 96 1 '100 931/2 95 95 __ *100 105 1051/2 IO6I/4 103 105 ♦100 __ 100 102 971/3 98 100 1001/2 110 iiiya 6-5% basis 96 98 ♦82 *5%% basis 104 __ 78 83 Qiy^ ♦103 100 __ •991/3 ♦79% 981/3 104 1051/a 36 __ 93 96 101 i02y. 80 soy. 8OI/2 81 96 96 30 79 81 98 70 75 891/2 __ 1 *100 55 70 ♦94 85 971/0 100 981/3 100 98 IO6I/2 84y3 104 _^ •loeva — •99y3 High Low Bid Asked Coll. Tr. 31/38, 1998 — — — 78 Deb. 4s, 1929 — — — 91 Michigan City & North. Indiana 1st 5s, 1933. — — *95 *97i/3 Michigan City Gas & Electric 5s, 1937 — __ 941/3 961/2 Michigan-Lake Sup. Pow. 1st 5s, 1945 — — *21 Michigan Power 1st 5s, 1911-16 — — — 98 Michigan State Tel. 5s, 1924 __ __ 991/2 lOQi/g Michigan Traction Co. 5s, 1921 — — *99 *102 Michigan Traction Extension Co. 5s, 1923 __ __ *93 *97 Michigan United Ry. Ref. 5s, 1936 „ — *90 *93 Middlesex & Boston St. Ry. Ref. 41/28, 1932— — — — *94 Middlesex & Somerset Trac. 1st 5s, 1950 — __ __ *97 Middlesex Valley 1st 5s, 1942 — __ __ *105 Middletown Horse R. R. 1st 5s, 1914 __ __ *4.40% basis Midland Cont'l R. R. 6% Notes, 1913-15 __ „ 5%% basis Midland Counties Gas & Elec. 68, 1932 __ __ 991/2 — Midland R. R. of N. J. 1st 53 Ex. to 1940 __ __ 105 lOTi/g Midland Terminal 1st 5s, 1925 — __ 97 Milford & Uxbridge St. Ry. 1st 5s, 1918 __ __ 100 Milford, Attleb. & W'nsocket St. Ry. 5s, 1919 >_ __ __ *100 Milford, Holliston & Fram. St. Ry. 5s, 1918___ __ __ __ 100 Millbury Water Ist 58, 1915 __ — __ 100 Millen & Southw. 5s, 1955 __ __ 90 Milliken Bros. Conv. 68, 1921 __ >_ *50i/3 *60 Mill Valley & Mt. Tamal's St. Ry. 5s, 1929— __ __ 100 Millville, Etna & Sharpsb. 1st 5s, 1923 __ __ 100 101 Milo Water Co. 1st 5s, 1929 __ __ *5% basis Milwaukee & Nor. Ex. 41/3S, 1913 __ __ 99% __ Milwaukee & Nor. Ex. 1st Cons. 6s, 1913 __ __ __ 99% Milwaukee & Nor. Ex. 1st 5a, 1931 __ __ ._ *98 Milwaukee & State Line 1st 31/2S, 1941 __ __ 84l^ __ Milwaukee El. Ry. & Lt. 5s, 1926 __ __ 103 IO41/3 Milwaukee El. Ry. & Lt. 41/28, 1931 __ __ 94 941/3 Milwaukee El. Ry. & Lt. Gen. & Ref. 5s, 1951 __ __ 951/3 96I/3 Milwaukee Gas Light let 4s, 1927 __ __ 891/3 91 Milwaukee, Lake Shore & Western. — Ext. 5s, 1929 __ __ 1071/3 — (Ashland Div.) 6s, 1925 __ __ ♦11414 __ (Marsh. Div.) 1st 5s, 1922 __ __ __ *104 (Mich. Div. 1st 6s, 1924 __ __ 11414 — 1st 6s, 1921 1111/2 1111/2 Milwaukee Light, Heat & Trac. 1st 5s, 1929— __ __ 100 102 Milwaukee, Sparta & Northw'n Ist 4s, 1947— 931/3 931/3 Minneapolis Brew. 7s, 1913 __ __ 101 Minneapolis Chamber of Com'ce 41/2S, 1913-22 __ — *100 Minneapolis Gas Light Gen. 58, 1930 __ __ 991/2 IOO1/2 Minneapolis General Elec. 1st 5s, 1934 __ __ 991/2 IOO1/2 Minn. & Pac. 1st 4s, 1936 — __ 95 Minneapolis & St. Louis R. R. — 1st 7s, 1927 _. — 105 Pac. Ex. 1st 6s, 1921 __ — — 109 Ist Con. 58, 1934 __ __ __ 110 1st & Ref. 4s, 1949 — __ — 78 6% Notes, 1914 __ __ 98i4 98y^ Minneapolis, St. Paul & S. S. Marie Ry. — 2d 48, 1949 — __ 90 Equip. «E" 41/2S, 1923 — — — "100 1st Cons. 48, 1938 __ „ 95 97 Minneapolis, S. Ste. Marie & Atl. 1st 4s, 1926 — — 961/3 __ 'Quotation nearest March 1, 1913. No quotation on that date. 1119 High Low Bid Asked Minneapols St. Ry. 2d 6s, 1913 __ __ 100 Minneap. St. Ry. (M. L. & M.) Cons. 5s, 1919 __ __ 101 Minneap. St. &. St. Paul City Cons. 5s, 1928__ _. _.. 1023^ lOSy^ Minneapolis Term. SMjS, 1950 __ __ 80 Minneapolis Union Ry. 1st 6s, 1922 „ __ 110% __ Minneapolis Union 1st 5s, 1922 __ __ 100 Minneapolis Union Ry. 1st 6s, 1922 __ — 100% __ Minnesota & Iowa 1st Zy^s, 1924 __ __ 91 Minnesota & Ontario Power 1st 6s, 1928 __ __ __ *99 Minnesota Transfer 1st 5s & 4s, 1916 __ __ __ *10iy^ Mission Trans. & R. Co. 5s, 1921 __ __ 95 100 Mississippi Central 1st 5s, 1949 __ __ 94 95 Mississippi Glass 1st 6s, 1924 __ __ __ *102 Mississippi River & Bonne T. 1st 5s, 1931 __ __ 99 lOOVg Mississippi River Power 1st 5s, 1951 __ __ *84 Mississippi Val. Gas & Elec. Coll. 5s, 1922 __ — 85 88 Missouri Edison Elec. 5s, 1927 — __ lOOVa 101 Missouri Elec. Lt. 6s, 1921 __ __ __ 1081/3 Missouri, Kan. & Eastern 1st 5s, 1942 __ __ 106 Missouri, Kan. & Okla. 1st 5s, 1942 __ __ IO31/2 1041/2 Missouri, Kansas & Texas Ry. — Cons. 5s, 1940 ._ __ 95 5s Notes, 1913 __ __ 99% lOOVg Ist 4s, 1990 __ __ „ 92% 2nd 4s, 1990 79 78I/2 1st Ex. 5s, 1944 __ __ 971/2 98% 1st & Ref. 4s, 2004 __ __ __ 76% Gen'l 41/2S, 1936 __ __ 84 St. L. Div., 2001 __ _« __ 771/2 Missouri, Kan. & Tex. of Texas 1st 5s, 1942— __ __ — 100% Missouri, Okla. & Gulf. 1st 5s, 1951 »_ __ 75 Missouri Pacific R. R. — 1st Con. 6s, 1920 __ _. 104% 105 Trust 5s, 1917 — — 99 991/2 Ist Col. Tr. 5s, 1920 98% 98% Col. 4s, 1945 69% 69% 1st Conv. 5s, "A," 1959 __ __ 86 87% 3rd 78 Ex. at 4s, 1938 __ __ __ 96I/2 - Equip. 5s, 1921 __ _. 5%% 5%% Equip. 5% Notes, 1914 __ __ 97 971/2 (Lex. Div.) 5s, 1920 __ „ 97 Missouri River Power 1st 6s, 1920 __ __ *102 *104 Mobile & Birm. P. L. 5s, 1945 _. „ 104 Gen'l 4s, 1945 __ __ 77 Mobile Elec. 5s, 1946 __ „ 90 92 Mobile Gas Deb. 6s, 1921 __ „ — "100 Mobile Gas 1st 5s, 1924 __ ._ '94 ^g? Mobile Light & R. R. 1st 5s, 1937 — — 95 97 Mobile Light & R. R. Cons. 5s, 1941 — __ 85 87 Mobile & Ohio R. R.— New 6s, 1927 ._ __ 116% 117% Ist Ex. 6s, 1927 __ __ _- 112% Gen'l 4s, 1938 . __ ._ 84% __ Montgomery Div. 1st 5s, 1947 __ „ IO81/2 110 St. Louis & Cairo Col. 48, 1930 ._ __ 88% — St. Louis & Cairo Gtd. 4s, 1931 >_ __ 91 92% Coll. 48, 1938 __ __ 85% 88% Equip. 5s to 1919 __ „ 5% 4%% Equip. 41/2S, 1916-22 __ — 5 4%% •Quotation nearest March 1, 1913. No quotation on that date. 1120 High Low Mobile Street R. R. 1st 6s, 1923 Mobile Term. & Ry. 6s, 1935 Mogul Mining 6s Mohawk Hydro Elec. 1st 6s, 1940 Mohawk & Mai. 4s, 1991 Mohawk & Mai. Cons. Zy^s, 2002 Monon Coal 5s, 1936 Monongahela Lt. & Pr. 5s, 1949 Monon. River Con. Coal & Coke 6s, 1949 Monongahela River R. R. 1st 5s, 1919 Monongahela St. Ry. 5s, 1928 Monongahela Valley Trac. Ist 5s, 1942 Montana Central Ist 6s, 1937 1st 45s, 1937 Montana Indep. Tel. 1st 6s, 1926 Montana Power Transm. 1st 5s, 1933 Montana Water 1st 6s, 1933 Monterey Lt. & Pow. 1st 6s, 1929 Montg. Lt. & Trae. 1st & Ref. 5s, 1942 Montg. Lt. & Trae. 6% Notes, 1914 Montg. Lt. & Water Pow. 1st Cons. 5s, 1943_ Montreal L., H. & P. 1st & Coll. 41/28, 1932— Montreal Lt. Ht. & Pr. 5s, 1933 Montreal Power Trans. 1st 5s, 1933 Montreal Street Ry. 41/38, 1922 Montreal Tramways 1st 5s, 1941 Montreal Tram. & Pow. 6% Notes, April, 1915 Montreal Tram. & Pow. 6% Notes, Jan., 1915 Montreal Water & Power, P. L. 41/2 s, 1932 Montville Street Ry. 5s, 1920 Morgan's La. & Tex. 1st 7s, 1918 Morgan's La. & Tex. Gtd. 6s, 1920 Morningside Elec. Street Ry. 1st 5s, 1935 Morris & Co. 1st 41/2S, 1939 Morris County (N. J.) Trac. 1st 5s, 1935 Morris & Essex 1st 7s, 1914 Morris & Essex 1st 7s, 1915 Morris & Essex 1st Ref. 3i/3», 2000 Morris & Somerset Elec. 5s,~ 1940 Mortgage Bond Co. 5s, 1932 Mt. Vernon Woodb. Cott. D'ck 1st 5s, 1949 Mt. Washington Street Ry. 1st 5s, 1933 Mt. Whitney Power & Elec. 1st 6s, 1939 Muncie & Union City 5s, 1936 Muncie Elec. Lt. 5s, 1932 Muncie, Hartford & Ft. W. 1st 5s, 1935 Municipal Gas & Elec. 1st 41/38, 1942 Municipal Serv. Coll. 5s, 1932 Muskegon Gas & Elec. 1st & Ref. 5s, 1926 Muskogee Gas & Elec. Ref. 5s, 1912-26 Muskegon, Gr. Rpds. & Ind. R. R. 5s, 1926 Muskegon Trac. & Lighting 1st 5s, 19^1 Muskogee Elec. & Gas 58, 1924 Muskogee Elec. Trac. 1st 5s, 1934 Mutual Fuel Gas 5s, 1947 Mutual Term, of Buffalo 1st 4s, 1924 Mutual Union Tel. 1st 5s, 1941 *Quotation nearest March 1, 1913. No quotation on that date. 1121 Bid Asked 99 100 95 100 *42i/2 *99 __ 95 80 921/2 95 961/2 991/2 1153/4 1021/2 — 100 101 96 124 IO8I/2 110 *54 *57i/2 *98 100 106 103 981/2 *98i/2 82 86 98 99 101 971/2 100 _ 1001/2 991/2 1001/2 'IOOI/2 __ 95 102 111% 1071/s ■" *101 88I/2 891/2 60 70 io2ys 1051/2 *86i/2 _- *100 991/2 751/2 76 1001/4 101 102 1021/2 81 86 951/2 98 89 92 95 961/2 90 95 95 971/2 *98 *96 79 *98 *93i/2 100 1011/2 *95 101 103 High Low Nashua St. Ry. 4s, 1931 Nash., Chat. & S. L. (Tracy City Br.) 68, 1917 Nash., Chat. & St. L. 1st 7s, 1913 1st Cons. 5s, 1928 Jasper Br. 1st 68, 1923 Centerville Br. 6s, 1923 Lebanon Br. 6s, 1917 Nashv., Flor. & Sheffield 1st 5s, 1937 Nashv. Gas & Htg. 1st 5s, 1937 Nashv. Ry. & Lt. 5s, 1953 Nashv. Ry. & Lt. Ref. & Ex. 5s, 1958 Nashville Street Ry. 5s, 1925 Nashville Water 4s, 1928 Nassau El. R. R. 1st 5s, 1944 Nassau Elec. R. R. Cons. 4s, 1951 Nassau Lt. & Pow. 1st 5s, 1927 Nassau & Suffolk Light 5s, 1935— Nat'l Breweries 6s, 1939 Nat'l Enam. & Stamp. 5s, 1929 Nat'l Gas, E. L. & P. Coll. 6s, 1931 Nat'l Lt., Ht. & P. Coll. "B" 5s, 1919 Nat'l Lt., Ht. & P. Coll. "C" 5s, 1920 National Rys. of Mexico. — Prior L. 41/38, 1957 Gtd. 4s, 1977 1. Prior L. 41/38, 1926 1st Cons. 4s, 1951 Coll. Tr. 41/2S, 1913 Nat'l Starch Deb. 5s, 1930 Nat'l Sugar Mfg. 1st 6s, 1933 National Tube 1st 5s, 1952 Natomas Cons. Co. of Calif. (Am.) 6s, 1930— Nebraska Land & Feeding 1st 6s, 1914-15 Nev.-Cal.-Ore. Ry. 5s, 1919 Nevada-Calif. Pow. 1st 6s, 1927 New Amsterdam Gas 58, 1948 New Bedford Extractor 1st Ref. 5s, 1933 New Bedford, Middleb. & Brock. 1st 58, 1920— New Bedford & Onset 1st 5s, 1922 New Brit. Gas Lt. 1st 5s, 1926 New Castle & Slien. Val. 6s, 1917 New Castle Lt., Ht. & Pr. 1st 5s, 1929 New Castle Water 1st 5s, 1932 New Departure Mfg 1st 6s, 1921 New England Brewing Ref. 5s, 1931 New Eng. Cotton Yarn 5s, 1929 New Engld. Pow. 1st 5s, 1951 New England R. R. 5s, 1945 48, 1945 (Boston Term'l) 48, 1939 New Engl. Tel. & Tel. 5s, 1915 58, 1916 Deb. 5s, 1919 4s, 1930 , Deb. 5s, 1932 New Gas Light 5s, 1934 New Haven & Centreville Ist 5s, 1933 New Haven & Derby Cons. 5s, 1918 New Haven & Northamp. Ref. 4s, 1956 ^Quotation nearest March 1, 1913. No quotation on that date. 1122 Bid Asked __ 921/4 104% __ 1001/2 1003/4 1071/3 108ya iiiy^ 110 __ 105 __ 108 98 1031/, 1001/2 101 97 98 1011/2 102 97 98 102 1031/4 77% 1001/2 1021/2 *95 __ ■5%% Basis 91 951/8 101 98 100 98 100 86 __ 80 99 767a 97% 98% 95 •85 98 983/4 9434 *100 __ 95 100 102 1011/4 101% ^102% 97 100 94 107 98 __ •77 _ ♦99 •99 __ ♦85 91% 92 92 110 __ 961/2 __ 1031/2 991/2 100% 991/2 lOOS/a 991/2 lOOS/s 88 90 101% __ i »103% 105 __ 100 __ 94 _„ High Low Bid Asked New Haven Street Ry. 1st 5s, 1913 — ._ 100 Edgew. Div. 5s, 1914 — — 100 New Haven Water, Deb. 4s, 1915 — — 155 N. J. & Hud. Riv. Ry. & Ferry 1st 4s, 1950— „ __ 82 83 New Jersey Gas 1st 5s, 1940 — — — 95ya N. J. Junction 1st 4s, 1986 — — 94 N. J. & N. Y. Ry. 1st 6s, 1950 — — 101 New Jersey Steamboat 5s, 1921 — — *87 New Jersey Zinc 1st 4s, 1926 — — *95 *98 New London Gas & Elec. 5s, 1927 — — 103 2nd 5s, 1929 — — 100 Cons. & Ref. 5s, 1933 — — 100 New London Northern 1st 4s, 1940 — — 92i4 — New Long Dist. Tel. 1st 5s, 1923 — — 791/4 SOi/g New Mexico Ry. & Coal 1st 5s, 1947 — — 98 101 1st Cons. 5s, 1951 — — 97 100 New Milford Pow. 1st 5s, 1932 — — 1021/2 IO41/2 New Orl. & CarroUton 58, 1933 — — 107% 108 New Orl. City & L. R. R. 1st 5s, 1943 — _. IO71/2 IO8I/2 New Orleans City & Lake Pow. House 6s, 1917 ._ — 102 New Orleans City R. R. 5s, 1943 __ >_ 1051/2 — New Orl. Cold Stge. & WTise. 6s, 1922 — — 100 110 6s, 1924 — — 100 New Orl., Gt. North. 1st 53, 1955 __ _- 67i/a 69 N. O., Mobile & Chic. 1st 5s, 1960 — — — 84% New Orl. & Northeast. Equip. 41/2S, Apr., 1913 — __ 6% _- N. 0. & Nor. Eastern Prior Lien 6s, 1915 __ — -_ 104 New Orleans Power 5s, 1943 *100 New Orleans Ry. & Lt. 41/2S, 1935 ._ — 85% 85% "A" 5s, 1949 — — 86 871/2 N. 0. R. E. Mtge. & Sec. 5s, 1926 *101i/2 — New Orl. Stk. Ex. 5s, 1924 *97i/2 — New Orl. Terminal 1st 4s, 1953 — — — 88 New Orl., Tex. & Mex. 5s, 1940 — — 92 95 New River Co. 1st 5s, 1934 — — 60 70 New River R. R. 1st 6s, 1932 — — 120 123 New Telephone Co. Cons. 53, 1920 __ — *84 New W'msburg & Flatb. R. R. 1st 41/2S, 1941_ „ __ _- *92 N. Y. Air Brake 6s, 1928 — — 991/2 101 New York Bay Ex. R. 1st 5s, 1943 — — 101 N. Y., Bklyn. & Man. Beach 1st Con. 5s, 1935. _. _- *102 New York Central Lines — 41/2 Notes, 1914 '_ — __ 993/g 99% Equip. 41/2S, 1922 — — 4.85-60% Basis Equip. 41/2S, 1925 __ _- 4.85-65% Basis Equip. 41/2S, 1927 — — 4.85-65% Basis Equip. 41/2S, 1928 — — 4.65% Basis Equip. 41/3S, 1917 — — — 101% New York Central & Hudson River R. R. — 1st 31/2S, 1997 — — 8414 841/2 Deb. 4s, 1934 89 89 Lake Shore 31/2S, 1998 — — — 7778 Mich. Cent. 31/2S, 1998 771/2 771/2 41/2% Notes, 1915 — — *99i4 *99i/3 N. Y., Chicago & St. Louis 1st 4s, 1937 __ __ — 98% Deb. 4s, 1931 — — — 87^8 N. Y. & Cuba Mail S. S. 1st 5s, 1932 — — *71iA ♦73 N. Y. Dock 4s, 1951 — — 83 N. Y. & East River Ferry 5s, 1922 — — 50 60 •Quotation nearest March 1, 1913. No quotation on that date. 1123 High Low New York & East River Gas 1st 5s, 1944 Cons. 58, 1945 N. Y. & Erie 1st 4s, 1947 2n(i Ex. OS, 1919 3rd Ex. 41/38, 1933 4th Ex. 5s, 1920 5th Ex. 4s, 1928 1st Ex. 7s, 1920 N. Y. Gas, E. L., H. & P. 1st 5s, 1948 P. M. 4s, 1949 N. Y. & Greenwood Lake 5s, 1946 N. Y. & Harlem SVgS, 2000 N. Y. & Hoboken Ferry 5s, 1946 N. Y. & Interurban Water 5s, 1931 N. Y. & Jersey E. R. 1st 5s, 1932 New York, Lackawanna & Western R. R. — 1st 6s, 1921 Construction 5s, 1923 Term. & Imp. 4s, 1923 N. Y., L. E. & Western 1st Cons. 7s, 1920 N. Y., L. E. & W. Coal & R. R. Co. 1st 6s, 1922 New Y., L. E. & W. D. & L Co. 1st 6s, 1913-_ N. Y. & Long Branch Gen. 4s, 1941 Gen. 5s, 1941 N. Y. & New England (Bost. Term.) 4s, 1939_ New York, New Haven & Hartford R. R.— Deb. 4s, 1914 4s, 1947 5% Notes, 1913 Deb. 31/28, 1947 1st 4s, 1954 Non-Conv. sy^s, 1954 Non-Conv. 4s, 1955 Non-Conv. 4s, 1956 Conv. 31/23, 1956 Conv. 68, 1948 122 122 N. Y. & N. J. Ferry 5s, 1946 N. Y. & N. J. Telep. Gen. 5s, 1920 N. Y. & N. J. Water Ist 5a, 1920 N. Y. & Northern 1st 5s, 1927 New York, Ontario & Western Ry. — Ist 4s, 1992 Genl. 4s, 1955 90% 9078 Ref. 43, 1992 5% Notes, 1915 Equip. 41/28, 1916 N. Y., Penna. & Ohio 1st 41/oS, 1935 N. Y. & Pa. Tel. & Tel. 1st 5s, 1926 Gen. 4s, 1929 N. Y., Phila. & Norf. 1st 4s, 1939 Inc. 4s, 1939 4% Stk. Tr. Ctfs., 1948 N. Y. & Porto Rico S. S. 58, 1932 N. Y., Prov. & Boston 4s, 1942 New York & Putnam 1st 4s, 1993 New York & Queens Co. 4s, 1946^ N. Y. & Q. E. L. & P. 1st C. G. 5s, 1930 N. Y. & Queens Gas 1st & Gen. 5s. 1934 N. Y. Rys. Adj. 5s, 1942 59 58% ^Quotation nearest March 1, 1913. No quotation on that date. 1124 Bid Asked 104 106 101 103 99 1021/2 104 100 ■ 103 104 92% 101 113 115 loiya 103% 84% __ 1031/2 109 86I/2 991/4 100 *74 *78 — 1021/, 1108/4 111 103 105% 961/4 971/4 113 1171/4 1071/4 lOOi/a 101 98 100 _ ~ ' »105 983/s 991/4 88 91% 100 100% 81% __ 98 82 _- 88% 8874 83 86 97 " 100 100 *78 106 107% ~ 90% *91i/2 "" 991/2 100 5% 4%% 94 __ 100 101 85 971/2 98% 90 92 __ •97% •95 95 96 93 96 65 75 100 101 98 100 High Low Bid Asked N. Y. Rys. 1st R. E. & Ref. 4s, 1942 . __ __ 761/2 77 N. Y. & Rich. Gas 1st 5s, 1921 __ __ 961/2 _- N. Y. & Rockaway Beach 1st 5s, 1927 __ __ 1031/2 105% N. Y. State Rys. 1st Cons. A 41/28, 1962 __ __ 921/2 941/2 New York & Stamford 1st 6s, 1931 __ >_ IO21/2 IO41/3 1st & Ref. 4s, 1958 _. __ 87 90 N. Y., Suburban Gas 1st 5s, 1949 ._ __ 102 105 New York, Susquehanna & Western R. R. — 1st 5s, 1937 __ __ 991/2 101% 2nd 41/3S, 1937 __ __ 821/2 90 Genl. 5s, 1940 __ __ ._ 87 Term. 1st 5s, 1943 __ __ __ IO71/2 N. Y. Telep. 1st & Gen. 41/2S, 1939 __ __ 97 97l^ N. Y., Westchester & Bost. 41/2S, 1946 97 97 N. Y. & Westch. Ltg. 4s, 2004 __ __ 821/3 85 Deb. 5s, 1954 __ __ 100 102 Newark Cons. Gas Cons. 5s, 1948 __ __ 103l^ __ Newark Gas 6s, 1944 __ __ I251/3 127 Newark Pass. Ry. Cons. 53, 1930 _> __ 105 106 Newburg & N. Y. 1st 5s, 1929 __ __ 100 Newburg Lt., Htg. & Pow. 1st 6s, 1921 __ >_ *98i/2*101 Newport & Cine. Bridge 41/2S. 1945 __ __ 100% __ Newport & Davton 1st 6s. 1917 __ __ 101 105 Newport & Fall Riv. St. Ry. 1st 5s, 1918 __ __ __ 101 Newport & Richford 1st 5s, 1941 __ __ __ 110 Newport News & 0. P. Ry. & E. C. 1st 5s, 1938 __ __ 98 IOOI/3 Genl. 5s, 1941 » __ 76I/2 771/2 Newpt. News Shipb. & Dry Dk. 5s, 1990 __ __ 95 Newtown Ry. 1st 5s, 1924 «, >. __ ♦9814 Niagara & Erie Pow. 1st 5s, 1941 __ _> 87 921/3 Niagara Falls G. & E. L. 1st 5s, 1921 __ >_ _. 97 Niagara Falls Pow. Ist 5s, 1932 __ __ 1021/3 102l^ Niagara Falls Pow. Ref. & Gen. 68, 1932 __ __ 105l^ 106 Niagara Lt., Ht. & Pr. 1st 5s, 1922 „ __ __ 100 Niagara L., H. & P. Cons. & Ref. 5s, 1925 __ __ __ 95 Niagara, Lockport & Ont. Pow. 1st 5s, 1954-_ __ __ 89l^ 921^ Niagara, St. Catharine & Tor. Ry. 1st 5s, 1929 __ __ _„ 99 Nipe Bay Co. 1st 6s, 1914 ._ _. _. 100% Deb. 6s. 1917 __ __ _. *100 Nodaway Valley 78, 1920 __ ._ 1031/3 _, Norfolk & Carolina 1st 5s, 1939 __ __ 108 112 Norfolk & Portsm. Trac. 5s, 1936 __ __ 9I1/3 92 Norfolk Ry. & Light 1st 5s, 1949 _> __ 99 991/3 Norfolk &' Southern R. R.— 1st 5s, 1941 __ __ 102% >_ 1st "A" 58, 1961 ._ __ 98% 98% 1st 5s, 1954 __ _- 95 991/2 Norfolk Street Ry. 1st 5s, 1944 ._ _- 104 Norfolk Term. 1st 4s, 1961 __ ._ 91 Norfolk Term. & Transp. 5s, 1948 __ __ ♦98 Norfolk & Washington Steamboat 5s, 1931___ __ __ 104% 105 Norfolk & Western Ry.— Equip. 4s "D," 1916 __ __ 4% -1/2% Basis Equip. 4s «G," 1916 „ .. 434.1/2% Basis Equip. 4s "M-0," 1917 „ __ 4.60-45% Basis Pocohontas Coal Jt. 4s, 1941 __ __ 891/2 QOV^ New River Div. 6s, 1932 __ __ 120 123 1st Cons. 4s, 1996 — — 96I/2 96% 1st Lien & Genl. 4s, 1944 ._ __ 91% 923^ ^Quotation nearest March 1, 1913. No quotation on that date. 1125 High Low 10-25-Y. Conv. 4s, 1932 10-20-Y. Conv. 48, 1932 105% 105% Conv. 41/28, 1938 Imp. & Ext. 6s, 1934 , Gen. 68, 1931 Norristown Transit 1st 5s, 1942 North Caro. Elec. Pow. 1st Ref. 1940 North. Caro. Pub. Serv. 1st Ref. 5s, 1934 North End Ry. 5s, 1915 North Hudson County Ry. 1st 6s, 1914 Cons. 5s, 1928 2nd Ext. 5s, 1924 North Hudson Lt., Ht. & Pr. 5s, 1938 North Jersey & Poc. Mtn. Ice 5s, 1919 North Jersey St. Ry. 4s, 1928 North Mtn. Water Sup. 5s, 1933 North Penna. Ist 4s, 1936 Genl. 3 3/lOs, 1953 North Platte Val. Irrig. Co. 6s, 1919 North Sh. Elec. 1st 5s, 1922 Ref. 5s 1940 _ North Shore Gas 1st 5s, 1937 North Spgld. Water 5s, 1928 North Sterling Irrig. Co. 6s North Wisconsin 1st 6s, 1930 Northampton, Easton & Wash. Trac. 5s, 1950 Northampton Traction 5s, 1933 Northeast Penna. 1st 5s, 1920 Northeastern R. R. of S. C. 6s, 1933 Nor. Cal. Power. Cons., Ref. & Cons. 5s, 1948_ Northern Calif. Power 5s, 1932 Northern Calif. Ry. 5s, 1929 Northern Central Gas 58, 1962 Northern Central Ry. Cons. 41/38 "E," 1925 — 5s "A," 1926 5s "B," 1926 Northern Colorado Power 5s, 1928 North. Conn. Lt. & P. 1st 5s, 1946 Northern Electric Co. 5s, 1955 Northern Elec. St. Ry. 58, 1957 North. Id. & Mont. Pow. 1st 6s, 1949 North, m. Lt. & Tr. 1st 5s, 1923 North. Ind. Gas & El. 1st Ref. 5s, 1929 Ry. Cons. 58, 1936 Northern Lake S. S. Co. 5s, 1912-21 Northern Maine Seaport & Term. 5s, 1935 Northern Ohio Rv. 1st 5s, 1945 North. Ohio Ry. Con. 5s, 1919 Nor. Ohio Trac. 5s, 1919 Nor. Ohio Tr. & Lt. 5s, 1933 Nor. Ohio Tr. & Lt. 4s, 1933 North. Ont. Lt. & Pow. Ist 6s, 1931 Northern Pacific Ry. — Prior Lien 4s, 1997 Genl. Lien 3s, 2047 St. Paul, Duluth Div. 1st 5s, 1916 Gt. Nor., C. B. & Q. Jt. 4s, 1921 100 100 Northern Pacific Term. 1st 6s, 1933 North. Ry. of Cal. 53, 1938 ^Quotation nearest Mard) 1, 1918. No quotation on that date. 1186 Bid Asked ~ 107% 104 104% 1211/4 119 122% •94% 92 97 921/2 96 98 __ 101 102 1031/4 98 100 621/2 70 80 81 103 1038/4 1001/2 102% 821/2 84% •30 102% __ 993/4 100% 951/2 97 *90 •95% 221/2 __ 119 •94 *98i/2 101 103 121 __ 903/4 __ 1003/4 102 1061/2 __ •95 102 104% 105 105 •74 ♦78 97% 98 95% 711/2 73% 60% 95 97 89 93 •901/4 5.20% Basis 95 100 102 100 100 103 90 80 — •95 97 97% 663/4 67% 99% 110% """ 108% — High Low Bid Asked North. Ry. of Costa Rica 5s, 1915 — „ __ 100 Northern Spgfd. Wtr. 5s, 1928 __ .. *95i/8 __ Northern States Power Coll. 6% Notes, 1917_ __ __ 991/2 lOOi/g North. States Trac. 5s, 1933 __ __ *10iy2 __ North. Tex. Elee. Coll. 5s, 1940 __ ._ 96 97i/a Northern Texas Trac. 1st 5s, 1933 __ __ 98 100 Northern Union Gas 5s, 1927 _. __ 100 102 Northeni Westch. Ltg. lat 5s, 1955 __ __ 98 99 Northumberld. Go. Gas & El. 1st, 58, 1946 __ __ 931/2 95 Northwestern Coal 5s, 1923 __ __ _« *98 Northwestern Elev. (Union Loop) 5s, 1945 __ 75 90 Northwestern Gas Lt. & Coke 5% Notes, 1917 __ __ 96% 96^8 Northwestern Gas Lt. & C. Cons. 5s, 1928 __ __ 100 Northwestern Penna. Ry. 5s, 1941 __ __ *98V2 __ Northwestern Telephone 4l^s, 1934 94 Northwest. Term. (D. W. W. & P.) 5s, 1926— — — 80 87 N. W. Union 7s, 1917 __ __ 109 Norwich Gas & Elec. 5s, 1927 __ __ 101 105 Norwich Street 1st 5s, 1923 __ _- 102 Norwich & Wor. 4s, 1927 ._ ._ 97 Norwood & Mont. 1st 5s, 1916 __ __ 101 Nova Scotia Stl. & Coal 5s, 1959 __ _. __ •941/2 Oakland Gas Lt. & Ht. 2nd 5s, 1916 __ __ 100 IOII/2 Oakland Rys. 6% Notes, 1913 __ __ __ *100 Oakland Traction Co. 5s, 1935 __ __ >_ 91% Oakland Traction Con. 5s, 1933 __ __ __ 98 Oakland Transit Co. 6s, 1918 __ ._ 107 Oakland Transit Co. 5s, 1931 __ __ 103 Oakland Transit Con. 5s, 1932 __ __ lOli/g IO214 Oakland Water 5s, 1915 __ __ 97 98iA Oakland Water Co. Gtd. 5s, 1937 __ __ 97 Ocean Freight Line 5s, 1913-22 __ __ *5.20% Basis Ocean Steamship Co. 5s, 1920 __ __ 99 101 O'Gara Coal 5s, 1955 __ __ 75 77 Ogden. Gas 1st 5s, 1945 __ __ 96l^ 97 Ogdensb. & Lake Champ. 1st 4s, 1948 __ __ 81 85 Ogilvie Flour Mills 1st 6s, 1932 __ ._ __ 105 Ohio & Little Kanawha R. R. 1st 5s, 1950 __ __ *100i/2 _- Ohio Cent. Cons. Tr. 5s, 1923 __ __ _. *90 Ohio Cent. Trac. 5s, 1919 90 Ohio Connecting Ry. Ist 4s, 1943 __ __ 97 Ohio Copper 1st 6s, 1917 __ __ _, *60 Ohio, Indiana & West. 1st Pfd. 5s, 1938 __ __ 90 Ohio River Railroad 1st Gtd. 5s, 1936 __ _. 108 Ohio River Railroad Genl. 5s, 1937 __ __ 101 llOi/g Ohio Traction 5s, 1936 __ __ __ 101 Oil Belt Co. 1st 5s, 1943 _. ._ _. *90 Okla. Cent. Ry. 5s, 1945 __ __ *28 Okla. Gas & Elec. 1st 5s, 1929 __ __ 92l^ 96 Okla. Nat'l Gas 1st Serial 6s __ __ 100 Oklahoma Ry. Ist 58, 1941 __ __ 92l^ 94l^ 1st & Ref. 5s, 1938 __ __ *93 *94i/3 Old Colony R. R. 48, 1924 — __ 95 97l^ 48, 1925 __ __ 95 971^ 4s, 1938 __ ._ 95 961/8 31/2S, 1932 ._ __ 88 891/2 Old Colony St. Ry. 4s, 1954 __ __ _^ *87 Old Dom. S. S. 1st 5s, 1913 >. ., *99l^ _. 'Quotation nearest March 1, 1913. No quotation on that date. 1127 High Olean Elec. Lt. & P. 1st 5s, 1951 Om. & Coun. Bl. Ry. & Edge. Ist Cons. 5s, 1928 Omaha & Council Bl. St. Ry. 1st 5s, 1928 Omaha Elec. Lt. & P. 1st 5s, 1933 Omaha Gas 1st Con. 5s, 1917 Omaha Gas Mfg. 1st 6s, 1914 Omaha St. Ry. Cons. 5s, 1914 *99% Omnibus Cable Ry. 6s, 1918 Oneonta Light & Pow. 1st 5s, 1922 Ontario Power 1st 5s, 1943 Deb. 69, 1921 Ontario Pulp & Paper 6s, 1931 Ontario & Quebec 5s Deb. Perp Ontario Transm. 1st 5s, 1945 Orange & Passaic Valley Ry. 1st 5s, 1938 Oregon & Calif. 1st 5s, 1927 ' Oregon Electric Ry. 1st 5s, 1933 Oregon R. R. & Navig. 4s, 1946 Oregon Short Line 6s, 1922 5s, 1946 107 4s, 1929 Oregon Short Line Ry. 4s, 1961 89% Oregon-Washington R. R. & Nav. 1st 4s, 1961 Oro Electric 1st 6s, 1951 Oswego & Rome 1st 7s, 1915 Oswego and Rome 2nd Gtd. 5s, 1915 Oswego & Syracuse 5s, 1923 Otis Elevator Deb. 5s, 1920 Otis Steel 1st 5s Ottawa Elec. Ref. & 1st 5s, 1933 Otto Electric Ss, 1933 Ottumwa Ry. & Lt. 1st & Ref. 5s, 1924 Ousatonia Water Pr. 4s, 1921 Ozark & Cherokee Cent. Ry. 1st 5s, 1913 Pacific Coast Co. 1st 5s, 1946 Pacific Coast Pr. 1st 5s, 1940 Pacific & Eastern Ry. 6s, 1937 Pacific Electric Ry. Co. 5s, 1942 Pac. Gas & Elec. (Ariz.) 1st 6s, 1931 Pac. Gas & El. (Cal.) Gen. & Ref. 5s, 1942 Pacific Gas & Elec. Ref. 5s, 1937 Pacific Gas Imp. 4s, 1930 Pac. Lt. & Pow. 1st 5s, 1942 1st & Ref. 5s, 1951 Pac. Pow. & Lt. 1st & Ref. 5s, 1930 Pacific Ry. of Mo. 1st Ex. 4s, 1938 2nd Ex. 5s, 1938 St. L. R. E. 5s, 1938 Carondelet 41/28, 1938 Pac. Telep. & Teleg. 1st Coll. 5s, 1937 Packard Motor Car 5% Notes, 1916 Paducah Trac. & Lt. Coll. 5s, 1935 Page Wov. Wire Fence 5s, 1922 Paint Creek Collieries 5s, 1956 * — Pan America R. R. 5s, 1934 Pardee Works 5s, 1931 Park & Ocean R. R. 6s Park & Tilford Deb. 68, 1936 'Quotation nearest March 1, 1913. No quotation on that date. 1128 Low Bid Asked __ 96 __ *97 'gg __ *97 '99 — 93V4 _. __ 97 99 - noiVa *99% — - 102% 95 951/2 97 971/2 99 -_ •94 122 124 91 921/2 94 96 102 __ 931/2 101 931/2 95 111 112% 107 89% _- 89% 901/2 90% 97 981/3 - 1011/2 _. 1051/a 100 _- 'lOOi/a - ♦931/2 — 100 — •lOO 85 881/a 4%% Basis ~ 991/2 .. __ - 1031/8 __ 991/2 1001/3 _- 'gs 1041/4 1041/3 101 102 88 89 951/2 95% 89% -. 971/2 100 93 g3 gs g2i/2 - 103 •102 __ •95 *100 __ 99% lOOi/s 971/3 g8i/2 __ 70 75 •68 ^72 39 41 - •911/3 •92 100 ♦95 •g6i/3 Parker Cott. Mills 6% Notes, 1917 Passaic Gas Lt. 6s, 1922 Lighting 58, 1925 - Water Gen. 5s, 1937 Water 2n(i 5s, 1937 Paterson & Pass. G. & E. 1st Cons. 5s, 1949 Paterson Ry. Cons. 6s, 1931 2nd 6s, 1914 Pawtucket Gas 4s, 1932 Pearsons-Taft "BBB" 4.40s "C" 4.40s «E" 4.60s "F" 4.80s Peekskill Ltg. & R. R. 1st 5s, 1930 Peerless Motor Car 1st 6s, 1913-24 Penmans, Ltd, 1st 5s, 1926 Penna Cen. L. & P. 1st & Ref. 5s, 1950 1st & Cons. 6s, 1963 ^ Penn-Mary Coal 5s, 1939 ' Penna. Cent. Brewing 6s, 1927 Penna. Coal & Coke 1st 5s, 1932 Pennsylvania Co. — 1st 41/28, 1921 Coll. "A" 81/2S, 1937 Coll. «B" 31/28, 1941 Coll. «C" 31/38, 1942 Coll. "D" 31/2S, 1944 Coll. "E" 4s, 1952 Coll. 4s, 1931 31/2S, 1937 Trust 31/2S, 1916 Penna. Lighting 1st 5s, 1940 Pennsylvania & Mah. Val. 5s, 1922 Penna. & Maryland Steel Cons. 6s, 1925 Pa. & N. Y. Canal Cons. 41/38, 1939 Cons. 4s, 1939 Penna. & N. Y. Canal Cons. 5s, 1939 Penna. & Northw. 58, 1930 Penn. Pub. Serv. 1st 5s, 1962 Pennsylvania R. R. — Col. T. 41/38, 1913 R. E. P. M. 48, 1923 Steel Rolling Stock, 31/3S, 1915 "A" Equip. 4s, 1914 Gen. Fr't. Equip. 4S, 1920 Equip. 4s, 1913-22 1st R. E. 4s, 1923 Cons. 5s, 1919 Cons. 31/2S, 1915 Cons. 4s, 1948 R. R. Cons. 4s, 1943 R. R. Cons. 31/3S, 1945 Penna. Steel 1st 5s, 1917 Penna. Steel Coll. 5s, 1932 Penna. Street Pass. Ry. 5s, 1922 _. Penna. Water Co. 2d 5s, 1929 Penna. Wtr. & Pow. 1st 5s, 1940 Penobscot 'Short Line 1st 48, 1920 Pensacola & Atlantic Ry. 1st 6s, 1921 'Quotation nearest March 1, 1913. No quotation on that 1129 High Low Bid Asked __ — noo __ __ *105 *102 __ __ *97 __ *90 _^ __ 1001/2 1021/2 __ 112 1131/3 __ 100 103 89 921/3 __ 94 __ _„ 94 95 _« __ 961/4 -. __ *95 *99 __ __ _- *100 901/4 941/4 971/3 981/3 __ — 100 __ __ - *983/4 64 ~ — 91 931/3 __ 102 103 *85 85% __ 85% -- - 95% __ *96 -- 95% __ 851/3 .. 961/2 __ 95 98 __ 101 1021/a __ __ 103 105 103 __ 98 -. 112 ^_ __ 1051/g 107 — — 95 ._ __ 991/3 - 1011/4 - 5-41/3% basis 98 5-41/2% basis 5-41/2% basis __ 1011/4 -- 106 107 96% 97% __ __ „ 102 __ — 101 *90 __ __ 998/4 100% __ __ •98% - __ •101% _- __ •99 __ __ - 92% __ __ •97% - __ •109 High Low Pensacola Elec. Co. 1st 5s, 1931 Peoples Gas L. & C. 1st Cons. 68, 1943 Peoples Gas L. & C. Ref. 5s, 1947 Peoples Pass. Ry. 4s, 1943 Peoples St. Ry. (Scranton) 1st 6s, 1918 Peoples Telephone 1st 5s, 1929 Peoples Water 5s, 1937 Peoria Gas & Elec. 5s, 1923 Peoria Light, Coll. 5s, 1936 Peoria & Eastern 1st Cons. 4 s, 1940 Peoria & Eastern Income 4s, 1990 Peoria, Bloom. & Champ. Tr. 1st 58, 1936 Peoria & Northw. sy^s, 1926 Peoria & Pekin Union 1st 6s, 1921 Peoria & Pekin Un. 2d 41/38, 1921 Peoria Ry. 1st 5s, 1910-26 Peoria Ry. Term. 4s, 1937 Pere Marquette R. R. — Cons. 4's, 1951 Deb. 6s, 1912 (Lake E. & Det. R.) 1st 41/28, 1932 41/2% Rec. Ctfs., 1914 Ref. 4s, 1955 Ref. 4s, 1955, gtd Pere Marquette R. R. of Ind. 1st 4s, 1943 Perkiomen R. R. 1st 5s, 1918 Perkomen R. R. 2nd 5s, 1918 Petersburg R. R. Class A 5s, 1926 Petersburg R. R. Class B 6s, 1926 Phila. & Bait. Cent. 1st 4s, 1951 Phila. & Chester Valley R. R. 48, 1938 Phila. & Erie Ist 6s, 1920 Genl. 5s, 1920 Phila. & Erie, Gen. 4s, 1920 Phila. & Garretsford St. Ry. 1st 5s, 1955 Phila. & Reading 2nd 5s, 1933 Phila. & Reading Imp. Ex. 4s, 1947 Phila. & Reading Cons. 4s, 1937 Phila. & Reading Term. 5s, 1941 Phila. & Reading Coal & L 4s, 1932 Phila. & West Chester Trac. 1st 58, 1918 Phila. & West Chester Trac. 4s, 1954 Phila., Balto. & Wash. 1st 4s, 1943 Phila. Bourse Ist 58, 1913 Phila. Co. 1st Coll. 5s, 1949 Phila. Co. Cons. 5s, 1961 Phila. Co. Conv. Deb. 5s, 1919 Phila. Co. Conv. Deb. 53, 1922 Phila. Elec. Coll. 5s, 1948 Phila. Elec. Coll. 4s, 1949 Phila. Elec. 4s, 1950 Phil., Germ. & Chest. Hill 1st 41/38, 1913 Phila. Harris. & Pitts. 1st 5s, 1925 Phila. Hydro. El. 1st 5a, 1939 Pittsb., McKeesp't. & Greensb. Ry. 1st 5s, 1931 Phila., Newtown & N. Y. 1st 3s, 1942 Phila. Rap. Tr. Coll. 58, 1957 Phila. Rap. Tr. 58, 1962 Phila. Suburban Gas 5s, 1931 Bid Asked 90 93 1151/2 117 101% 101% 90 91 104 1071/3 57 60 813/4 81% 100 1003/4 96 99 90 431/4 48 99 1003/4 90 102 95 __ *97 85 ~ 70 731/3 20 40 85 92 5% basis 591/3 51 54% 70 76 1021/4 1031/, 102 1031/, 106 114 971/2 981/4 *92 110 111 1041/2 1051/2 99 991/3 *89 1121/2 1131/3 981/2 991/4 981/3 991/4 1133/4 1141/4 971/2 99 99 100 80 82 99% 99 100 1001/2 1011/4 921/3 104 981/3 1031/2 104 801/3 8I1/4 8II/4 8iy, 98 106 107 100 76 82 76 79 991/3 100 98y, 99 104 _„ ^Quotation nearest March 1, 1913. No quotation on that date. 1130 High Low Phila. Sub. G. & E. 1st & Ref. 5s, 1960 Phila. Trac. Coll. 4s, 1915, 1917 Phila., Wil. & Bait. Deb. 4s, 1917 Phila., Wil. & Bait. Deb. 4s, 1922 Phila., Wil. & Bait. Deb. 4s, 1926 Phila., Wil. & Bait. Deb. 4s, 1932 Phila. Wil. & Bait. Col. 7.40 1,921 Philippine Ry. 1st 4s, 1937 Pierce Bldg. 5s, 1936 Pillsbury-Washburn Fl. Mills 5s, 1928 Pine Bluff & West. Ist 5s, 1923 Pine Creek Ry. 1st 68, 1932 Pine Hill Coal 6s, 1914 Pitcairn & Wilmerding St. Ry. 1st 5s, 1931 Pittsburgh Alleg. & M., 5s, 1930 Pittsburgh & Bifniingham Tr. 5s, 1929 Pitts., Bess. & L. E. Con. 5a, 1947 Pitts., Bess. & L. E. Deb. 5s, 1919 Pittsb. Brew'g. 6s, 1949 Pitts.-Buff. 5s, 1929 Pitts.-Cannonsburg & Wash. Ry. 5s, 1917 Pittsb. & Charleroi 5s, 1932 Pittsb., Chartiers & Yonghiogheny Ry. 4s, 1932 f*ittsburgh, Cine, Chic. & St. Louis R. R. — "B" 41/2S, 1942 "D" 4s, 1945 "G" 4s, 1957 "H" 4s, 1960 Cons. "A" 41/28, 1940 Cons. "C" 41/2S, 1942 Cons. "E" 31/28, 1949 Cons. "F" 4s, 1953 Pitts., Cleve. & Toledo 1st 68, 1922 Pittsburgh Coal 1st 5s, 1954 Pitts. Coal Deb. 5s *91i/2 89% Pittsburgh Coal Equip, 41/2S, 1914 Pitts. Crucible Steel 1st 5s, 1916-45 Pittsb. Gas 5s, 1956 Pitts. & Jamestown R. R. Ist 6s, 1922 Pittsburgh June. 2nd 5s, 1922 Pittsburgh June. 1st 6s, 1922 Pitts. & Lake Erie 1st 6s, 1928 Pitts. & L. E. 2d A & B 5s, 1928 Pitts., McKeesp. & Connells. R. R. 1st Cons 5s, 1931 Pitts., McKeesp't. & Greensburg Ry. 1st 5s, 1931 Pitts., McK. & Y. 1st 6s, 1932 Pitts, McK. & Y. 2nd 6s, 1934 Pittsburgh & Shawmut 1st 58, 1959 Pittsburgh & Shawmut Notes 6s, 1913 Pitts., Shawmut & N. Ist 5s, 1949 4s, 1952 Receiver's Cfs. 5s, 1914 Receiver's Cfs. 5s, 1915 Receiver's Cfs. 5s, 1916 Pitts., Shenango & Lake E. 1st 5s, 1940 Pitts., Shenango & Lake E., Cons. 58, 1943— Pitts. Term. R. R. & Coal 1st 5s, 1942 •Quotation nearest March 1, 1913. No quotation on that date. 1131 Bid Asked 93 931/2 93 96 981/2 100 99 100 99 100 98 100 981/2 *84 95 *72 961/2 100 *120i/2 ■^10014 ' "1921/2 1021/2 1031/2 102 102% 109 110 98 101 923/4 95 1001/2 1011/2 *98i/4 101 1011/2 — *90 103 1033/« 98 951/2 96% *98 105 102 90 951/4 1121/4 _. 109 ~ *4%% basis 1 *100 *74 *109i/2 90 *109i/8 114 106 ~ 102 — *76 •82 116 116 85 94 991/2 100 36 25 32 97 100 98 98 100 IO8I/4 109 110 93 97 High Low Bid Asked Pittsb. Term. Wareh. & Trans. 1st Ref. 5s, 1936 - - 991/4 1011/2 Pittsb. Trac. 1st 5s, 1927 — — 103 103 Pitts., Va. & Charleston Ry. 1st 4s, 1943 __ — 9514 __ Pittsburgh & West. 1st 4s, 1917 — — 971/3 — Pittsb.-Westmoreland Coal 1st 5s, 1947 — __ 84 86 Pittsb.-Westmoreland Coal 5s, 1925 __ __ 94 96 Pitts., Wheel. & Lake E. Coal 4s, 1931 __ __ 34 45 Pitts., Youngs. & Asht. 4s, Ser. A., 1948 __ __ __ 99% Pitts., Ygston & Ash. 1st Con. 5s, 1927 __ — 1061/2 IO81/2 Plainfield Union Water 1st 5s, 1931 *101 *101 Piatt Iron Works 5s, 1944 „ — __ *65 Plattsb. Gas & El. 1st 5s, 1939 __ __ — 96 Pleasant Valley Coal 5s, 1928 — — 88 95 Pneumatic Scale Corp. 1st 7s, 1917 — — *97 Pocahontas Coal & Coke— N. W. jt. 4s, 1941_ __ __ 891/2 901/2 Pocahontas Collieries 1st 5s, 1937 — — — *98 Pocahontas Cons. Coll. 5s, 1957 — — 87iA 88 Pomona Cons. Water bonds __ __ 99 Pontiac Light & Water 5s, 1927 __ __ *90 Pontiac Realty 5s, 1922 __ __ — 87 Pope Mfg. 6% Notes, 1914 „ „ — *100 Port Huron Ltg. & Pr. 5s, 1921 — — *101 Portland & Cape Eliz. 5s, 1915 __ __ __ 100 , Portland (Me.) Elec. 5s, 1926 __ — 99 101 Portland (Me.) Gas Light 1st 4s, 1936- __ __ „ *100 Portland (Me.) Lighting & Pr. 1st 41/2S, 1921 __ — — *99i/2 Portd. (Ore.) Gas & Coke 1st & Ref. 5s, 1940 __ __ 101 103 Portland (Ore.) Gas 1st 5s, 1951 __ __ 103 Portland (Ore.) Gen. Elec. 1st 5s, 1935 „ __ __ *101i/o Portland, Nehalem & Seacoast Ry. 1st 5s, 1942 *90 *90 Portland & Ogdens, 1st 41/2S, 1928 __ __ 100 101 Portland R. R. 1st 41/3S, 1913 __ __ 100 Portland R. R. 1st Cons. 31/2S, 1951 __ __ 75 80 Portland Ry. 1st & Ref. 5s, 1930 __ „ lOliA IO21/2 Portland Ry. Lt. & Pr. 5% Notes, 1914 __ __ 981/2 991/3 Portland Ry., L. & P. 1st & Ref. A 5s, 1942-_ __ __ __ 96 Portland & Rumford F. 1st 4s, 1926 __ __ 94 96 Deb. 4s, 1927 __ __ 93 Portland Terminal 1st 4s, 1961 __ __ 91 91% Portland Water 4s, 1927 __ __ 971/2 98 Porto Rico Brew. 1st Serial 6s *100 *100 Porto Rico Rys. 1st 5s, 1936 __ __ __ 89% Porto Rico Rys. 5s, 1962 __ __ '91 Porto Rico Telephone 1st 7s, 1937 __ __ __ *100 Port Reading R. R. 1st 5s, 1941 __ __ *106 Portsmouth, Berkley & Suffolk Water 5s, 1944 __ __ __ *100 Portsmouth Gas 1st Ref. 6s, 1931 __ ._ __ *99i/a Portsm., Gt. Falls & Conway 41/2S, 1937 __ „ 98 100 Portsmouth St. Ry. & Lt. 58, 1916 __ __ *98i/2 — Postal-Teleg.-Cable 1st 58, 1928 'lOO 'lOO Potomac El. Pow. 1st 5s, 1929 __ __ 104% 10514 Potomac El. Pow. Cons. 5s, 1936 __ __ 100% 102 Potomac Valley 1st 58, 1941 1_ __ 105 Potts. Run Land 1st 5s, 1953 «_ __ __ *80 . Powell River Co., Ltd., 1st 6s, 1915-27 *100 *100 Prescott Gas & EI. 1st 6s, 1940 >_ __ 85 89 Price Bros. & Co., Ltd. 1st 58, 1940 __ __ __ 86 'Quotation nearest March 1, 1913. No quotation on that date. 1132 High Low Bid Asked Princeton & Northwestern SVgS, 1926 — __ *90 Princeton Lt., Ht. & P. 1st & Ref. 5s, 1939— __ — — 98 Producers Oil Deb. 6s, 1913 — — *96 *102 Prod. Transportation 5s, 1921 _ — — 92% __ Providence Securities Deb. 4s, 1957 — — — 84 Providence Terminal 1st 4s, 1956 — — 95 Prov. & Wore. 4s, 1947 — — 96 971/3 Provident Loan Soc. of N. Y. 41/2S, 1921 — — 95 97 Provincial Lt., Ht. & P. 1st 5s, 1946 — — 103 1031/2 Pub. Serv. Co. of Nor. 111. 1st & Ref. 5s, 1956 — — 96% 9714 Public Serv. Co. (St. Cloud, Minn.) 5s, 1911-30 — — 5.40% basis Pub. Serv. Corp. of N. J. Perp. 6s, Ctfs — — 106 107 Pub. Serv. Corp. of N. J. Gen. 5s, 1959 __ — 9II/2 92 Public Utilities Corp. 6% Notes, 1914-16 __ __ — *101 Pueblo & Subur. Tr. & L'tg. 1st 5s, 1922 __ — 921/2 — Pueblo Trac. & Ltg. 1st 5s, 1921 — — 971/2 100 Puget Sd. Elec. Ry. Cons. 5s, 1932 __ — 85 92 Puget Sd. Mills & Timber 6s, 1926 *100 *100 Puget Sd. Power 1st 5s, 1933 — — 99 IOII/3 Puget Sd. Trac, Lt. & Pr. 5s, 1914 — — 991/3 100 Quannah, Acme & Pac. 1st 6s, 1939 __ __ — *101 Quapaw Gas 1st 6s, 1912-21 — — *85 Quebec, Jacques, Cartier Elec. 1st Ref. 5s, 1931 — — — *87 Quebec Ry., Lt., Ht. & P. Cons. 5s, 1939 __ __ 571/3 58 Quebec Ry., Lt., Ht. & P. 5s, 1942 __ __ 56 57 Queensboro Corp. (N. Y.) 1st 6s *100 *100 Queensboro Gas & El. 1st 5s, 1952 — — 97 100 Quincy Gas & Elec. 5s, 1929 — __ 93 Quincy Gas, Elec. & Ht. 1st Cons. 5s, 1935___ __ — 851/2 90 Racine Water 5s, 1931 — — 96 971/3 Rail & River Coal 1st 5s, 1938 __ __ *90% __ Railroad Secur. 1st 4s, 1952 — — *82 *85 Railway & Lt. Secur. 2nd 5s, 1939 — — — *100 Railway & Lt. Secur. 4th 5s, 1932 __ — *5% basis Railway Steel Spr. 5s, 1921 (Latrobe PI.) — — — 98i/8 Railway Steel Spring 1st 5s, 1931 __ „ 94 97 Raleigh & Augusta 1st 6s, 1926 __ — — II31/2 Raleigh & Cape F. 1st 5s, 1943 — — 98 103 Raleigh & Charleston R. R. 1st 4s, 1956 — __ — *85 Raleigh & Charleston R. R. Cons. 4s, 1956 — — — *72i/3 Raleigh & Gaston Ist 5s, 1947 — — IO71/3 — Raleigh & Southp. Con. 5s, 1965 __ — 97 102 Raleigh & S. W. 1st 4s, 1936 __ __ 80 Rapid City Ry. 1st Cons. 5s, 1916 __ — 90 Rapid Ry. 1st 5s, 1915 — — — *100 Rapid Transit St. Ry. 1st 5s, 1921 — __ 103 Raritan River 1st 5s, 1939 __ — 108 II21/3 Rav., Spenc. & Glen. 1st 6s, 1920 — — 105 Ray Cons. Copper 6s, 1921 IIII/2 IIII/3 Reading Belt R. R. 1st 4s, 1950 — — *96i/2 — Reading Co, — Gen. 4s, 1997 96I/2 96I/3 Jer. Cent. 4s, 1951 — — — 96I/2 Ext. 4s, 1937 __ _- — *99i/2 Phil. & Read. Coal & Ir. 4s, 1997 — — — *97% Reading Traction 1st 6s, 1933 __ __ 112 117 •Quotation nearest March 1, 1913. No quotation on that date. 1133 High Low Bid Asked Reading & Womelsdorf Elec. Ry. 1st 5s, 1925 — ._ 100 102 Real Estate Title Insur. & Trust 4s, 1918 ^931/4 *93y4 Red River, A. & B. B. Dist. (La.) "Ser. B" 6s, 1950 *107 Red River, A. & B. B. Dist. (La.) "Ser. C" 5s, 1953 *109 Red River Power 1st 5s, 1915 — — — *93 Reeves Timber Ist 5s, 1923 *100 *100 Reno Pw., Lt. & Wtr. 6s, 1944 — — 95 Rensselaer & Saratoga 1st 7s, 1921 — — 117 Repub. Iron & Steel 5s, 1934 — — 10278 — Repub. Iron & Steel 5s, 1940 911/2 911/2 Republic Ry. & Lt. 5s, 1916 — — 96 971/3 Republican Valley 1st 6s, 1919 __ __ 102 Retsof Mining Ist 5s, 1925 — __ 56 60 Rhode Island Suburban 1st 4s, 1950 — — 85 87 Rich. & Alleghany 1st 4s, 1989 __ — 91% 94 Rich. & Alleghany 2nd 4s, 1989 — — *88 *89 Richmond & Danville 6s, 1915 — — — 103 Richmond & Danville 5s, 1927 — — — 103 Rich. Fredkbg. & Potomac 41/2S, 1940 __ — IO31/2 — Richmond, Light & R. R. 4s, 1952_ — — *65 "70 Richmond & Mecklinburg 1st 4s, 1948 __ — 72 Richmond & Peters. 6s, 1915 — — 106 Cons. 7s, 1915 — — 109 Cons. 41/2S, 1940 — — 101 Richmond- Washington Co. 4s, 1943 „ ._ 90 97% Riggs Realty 5s, 1923-40 — — IO21/2 103 Riggs Realty 5s, 1913-23—^ — — 101 103 Rio de Jan. Tram., Lt. & Pr. 1st 5s, 1935 „ — 98 Rio Grande June. 1st 5s, 1939 ._ __ 83% 841/3 Rio Grande Southern 1st (gtd.) 4s, 1940 __ __ — 771/2 Rio Grande Southern 1st 4s, 1940 __ __ *40 *50 Rio Grande Western 1st 4s, 1939 841/3 841/3 Rio Grande Western Col. A 4s, 1969 __ „ — 80 Riordon Pulp & Paper Ist 6s, 1942 *100 'lOO __ ' __ Ritz-Carlton Hotel (Mont.) 1st 5s, 1942 — — — *95 River Coal 6s, *116i/4 *115% Riverside Home Tel. & Tel. bonds — — 50 Riverside Traction 1st 5s, 1960 __ — — *97i/8 Roanoke Gas Lt. 1st 5s, 1927 — — — 961/2 Roanoke Ry. & Elec. 1st 5s, 1949 __ __ 95 Roanoke Ry. & Elec. 1st Cons. 5s, 1953 __ -_ — 98 Roanoke Trac. & Light 1st & Coll. 5s, 1958— __ __ 921/2 95 Roch. & Pitts. Coal & Iron 1st 41/2S, 1932 — — 93% __ Roch. & Pitts. Coal & Tr. 5s, 1946 _- — 100 Roch. & Pitts. 1st 6s, 1921 __ — 110% — Roch & Pitts. Cons. 63, 1922 — — 112 Roch. Elec, Lt., Heat & P. 1st Ref. 6s, 1943— __ — — 100 Roch. Gas & Elec. 2nd 4i/oS, 1920 — — 96i/a — Rochester Ry. Cons. 5s, 1930 — — 102 Rochester Ry. 2nd 5s, 1933 — — 102 104 Roch. Ry. & Light Cons. 5s, 1954 __ __ 100% __ Roch., Syracuse & Eastern Ist 5s, 1945 __ — 83% 841/3 Rochester Telephone 1st 5s, 1920 -_ — 95 100 Rochester Telephone Gen. 5s, 1933 _- — 75 90 Rock I. & Peoria 6s, 1925 — — 101 Rock Id., Ark. & Louis'a. r.st 41/28, 1934 __ — — 87% Rock Id.-Frisco Term. Ist 6s, 1927 — — 99 100 *Quot&tloD nearest March 1, 1913. No quotation on that date. 1134 High Low Bid Asked Rock Island Imp't. Co. 41/28, 1915 __ _- — *99 Rock Island Southern 1st 5s, 1947 — — — 95 Rockford & Freeport Elec. Ry. 1st 5s, 1923_- — — 92 96 Rockford & Inter-Urban Ry. 1st 5s, 1923 — — 93 96 Rockford, Beloit & Janesv. 1st 5s, 1930 __ _- 92 96 Rockford Elec. 1st & Ref. 5s, 1939 -_ — 961/2 98 Rockford Home Telephone 1st 6s, 1922 — — *95 Rockland Light & P. 1st 53, 1938 — — — 100 Rockland Rockport Lime 5s, 1920 __ — 51/2% basis Rockville Gas & Elec. 5s, 1936 — — 5% basis Rogers-Brown Iron 1st & Ref. 5s, 1914-40 — — 90 96 Rogue River Water 5s, 1926 — — — *88 Roland Park Water 1st 5s, 1937 — — *97 *99 RoUand Paper 1st 6s, 1937 — — — 100 Rome Gas, El., Lt. & P. lat 5s, 1931 — — 90 Rome Ry. & Lt. 1st 5s, 1937 — — — 90 Rome, Watertn. & Ogden. 31/2S, 1922 __ — 90 Rome, Watertn. & Ogden. Cons. 5s, 1922 __ __ IO61/2 . — Rome, Watertn. & Ogden. Term. 5s, 1918 — — ^Vi% basis Rumford Falls Pow. 1st 4s, 1945 __ — — 921/, Rumford Falls Pow. Gen. 41/2S, 1929 — — — 99 Rumley Co. 6% Notes 1915 — — — 100 Rutland Canadian 4s, 1949 — — 85 87 Rutland R. R.— 1st Cons. 41/28, 1941 — — 92l^ 97% Equip. 41/28, 1913-27 — — 6-51/2% basis Car. Tr. 41/2S, 1917 — — 5-6% basis Rutland Ry., Lt. & P. 1st 5s, 1946 — — 94 97 Sacramento & Woodland R. R. 5s, 1941 — — 951/2 — Sacramento Elec, Gas & Ry. 5s, 1927 — — 102% 103 Sacramento Val. Irrig. 1st 6s, 1920 — — *100 Sacramento Valley P'r. 6s, 1941 __ — — *100 Safety Insulated Wire & Cable 6s, 1942 — — *78 Sagman-Bay City Ry. 1st & Ref. 5s, 1935 ._ — 86 91 Sagman City Gas 5s, 1916 — — 97 99 Saginaw, Tusc. & Hur. 1st 4s, 1931 — — — 90 Saginaw Valley Trac. 5s, 1920 >- — 98 100 St. Charles Street R. R. 4s, 1952 — — 90 St. Clair County Gas & Elec. 1st Cons. 5s, 1959 __ __ 90 95 St. Clair Furnace 1st 5s, 1913-39 — __ 4.90-70% basis St. Clair, Mad. St. L. Belt (A. B.) 1st 4s, 1951 _- — — 781/2 St. Clair Term. 1st s5, 1932 __ __ 99 102 St. Clair Steel 1st 5s, 1912-25 — — 4.60% basis St. Cloud Water Power 68, 1916-39___ — „ — *100 St. Croix Paper 5s, 1913-27 — — 51/4% basis St. Croix Power 1st 5s, 1929 — — *94i/2 __ St. Francois Co. Ry. 5s, 1914 — — *100 St Joe Bay Co. 1st 6s, 1918 — — — *90 St. John Ry. Cons. 5s, 1927 — — *5% basis St. Johnsb. & Lake Champ. 1st 5s, 1944 ._ — 102 St. Joseph Gas 1st 5s, 1937 — — 92 96 St. Jos. & Grd. Isld. 4s, 1947 — — — 87 St. Jos. Ry., Lt., Ht. & P. 1st 5s, 1937 — — 98I/2 99% St. Joseph Stock Yds. 41/2S, 1930 — — 87 St. Joseph Water 58, 1941 — — — 5.20% basis St. Law. & Adir. 1st 58, 1996 __ — 106 110% 2nd 6s, 1996 — — 119 St. Lawrence Pulp & Tbr. 6s, 1916-33 __ — *100 •Quotation nearest March 1, 1913. No quotation on that date. 1135 High Low Bid Asked St. Lawrence Segar Refin. 6s, 1933 __ «_ __ *102 St. Louis & Cairo 1st 4s, 1931 __ __ *91 *923^ St. Louis & Meramec 6s, 1916 _.. __ 102 103 St. Louis & San Francisco Ry. — (Miss. & West.) 6s, 1919 __ __ __ ♦1053^ 6s, 1920 __ __ 101 Eq. "I" 5s, 1917 __ __ 5l^% 5% basis Col. Trust 5s, 1987 __ __ 98 100 6% Notes, 1913 __ , __ 995/8 100 6% Notes, 1914 __ __ 99% >_ N. O. T. & M. 5s, 1940 __ __ 92 95 Gen. 6s, 1931 >_ __ 113% lUi/g Gen. 5s, 1931 __ __ 1021/2 1043^ Gen. 4s, 1996 ._ __ __ 87 15-20 yr. 5s, 1927 __ __ 793/8 79% Southn. Div. 5s, 1947 — __ 991/2 __ Ref. 4s, 1951 76 76 Eq. "G" 41/2S, 1916 •993^ __ Eq. "L" 5s, 1908-17 __ __ __ 'lOOi/g Eq. «S" 5s, 1912-23 __ __ __ *99 St. Louis & Southw. 1st Term 5s, 1952 __ __ 89 901/2 St. Louis & Suburban 1st 5s, 1921— __ __ 101 102 St. Louis & Suburban Gen. 5s, 1923 __ >_ 85 85% St. L. Brew. Ass'n. 6s, 1914 — __ 998^ lOOyg St. Louis Bridge 1st 7s, 1929 ._ >_ >_ 129 St. Louis County Gas 1st 5s, 1951 __ __ __ 99 St. Louis Iron Mt. & Sou. Equip. 5s, 1921 __ __ 991/2 100% St. L. Iron Mt. & Sou. Equip. "I" 5s, 1914-15 __ __ __ *100% St. L. Iron Mt. & Sou. Genl. 5s, 1931 104% 104% St. L. Mt. & Sou. Unif. & Ref. 4s, 1929 „ „ 8I1/2 82 St. L. Iron Mt. & Sou. Riv. & Gulf Div. 1st 4s, 1933 __ __ 83 83% St. L. Merch. Bridge Term.- Co. 5s, 1930 __ __ 104% __ St. L. Merch. Bridge Co. 6s, 1929 ._ __ 110 111% St. Louis Nat. Stockyards 1st 4s, 1930 __ __ *84 St. Louis Portland Cement __ __ 99% 99 St. Louis Ry. (B'way) 41/2S, 1920 __ __ 96% 97% St. Louis Real Est. 1st 5s, 1938 __ __ 101 St. L. ,Rky. Mtn. & Pac. 5s, 1955 >_ __ 76% 77% St. Louis, Southern 1st 4s, 1931 __ __ __ 95% St. Louis Southw'n, 1st 4s ctfs., 1989 __ __ __ 88% 2nd 4s Inc. Ctfs., 1989 __ __ 78 79 Cons. 4s, 1932 __ >_ 79 80% St. Louis, Spring. & Peoria Ist Ref. 5s, 1939— — — — 100 St. Louig Sugar Refineries 6s, 1932 — — 578% basis St. L. Transit 5s, 1924 __ __ 70 76 St. Louis Union Depot Cons. 5s, 1944 __ — __ 102% St. L., Wichita & West. 6s, 1919 __ __ 100 St. Maurice Val. Cotton Mills 1st 6s, 1952 — — — *96 St. Paul & Duluth 1st 5s, 1931 __ __ 109 St. Paul & Duluth 2nd 5s, 1917 — — 101 St. Paul & Duluth 1st Con. 4s, 1968 — __ — 93 St. Paul & Kan. City Short Line 1st 4%s, 1941 __ — — 89 St. Paul & North. Pac. Genl. 6s, 1923 — — 113 St. P. & Nor. Pac. (Reg.) Genl. 6s, 1923 — — 11134 __ St. Paul & Sioux City 1st 6s, 1919 — — 108s/8 110 St. Paul City Ry. 5s, 1937 — — 104 106 St. Paul City Ry. 1st 6s, 1932 >_ __ 111 St. Paul City Ry. 1st Cons. 6s, 1934 — __ 112 •Quotation nearest March 1, 1913. No quotation on that date. 1136 St. Paul City Ry. Cable 5s, 1937 St. Paul, Eastern Grd. Trk. Ry. 41/2S, 1947 — St. Paul Gas Light Con. ext. 6s, 1918 St. Paul Gas Light Con. 1st 6s, 1915 St. Paul Gas Light Gen. 5s, 1944 St. Paul, Minn. & Manitoba 4y2S, 1933 St. P., M. & M. Cons. 4s, 1933 St. P., M. & M. 1st Cons. 6s, 1933 St. P., M. & M. Mont. Ext. 48, 1937 St. P., M. & M. Pac. Ext. 4s, 1940 St. Paul Union Depot Cons. 5s, 1944 St. Paul Union Stk. Yds. 5s, 1916 Salisbury & Spencer 1st 5s, 1945 Salmon Riv. Power 5s, 1952 Salt Lake & Ogdensbg. 5s, 1934 Salt L. City Un. Dep. & R. R. 1st 5s, 1938 San Ant. & Aransas Pass. 1st 4s, 1943 San Ant. Water Supply 1st & ref. 5s, 1933 San Cristobal Sugar 7s, 1932 San Diego Cons. G. & E. 5s, 1939 S. F. & Nor. Pac. 1st 5s, 1919 San Fran. & San Joa. Valley 1st 5s, 1940 S. F. Elec. Rys. 5s, 1932 San Fran. Gas & Elec. 41/2S, 1933 S. F. Napa & Calistoga Ry. 6s, 1936 S. F., Oak. & San Jose Ry. 5s, 1933 S. F., Oak. & San Jose Ry. 2nd Mtg. 5s, 1933_- S. F., Oak. & San Jose Con. Ry. 5s, 1938 San Joaquin Lt. & P. 1st & Ref. 6s, 1950 San Joaquin Lt. & P. 1st & Ref. 53, 1950 San Joaquin Lt. & P. 1st 5s, 1945 S. J. & S. Clara. R. R. 41/33, 1946 Sanford & St. Petersburg 4s, 1924 Santa Barbara G. & E. Ist 6s, 1941 Santa Fe, Prescott & Phoenix 5s, 1942 Santiago Elec. Lt. & Trac. 1st 6s, 1959 San Paulo Tram., L. & Pr. 1st 5s, 1929 Sault Ste Marie & So. W. 5s, 1915 Sault Ste Marie Edge. 1st 5s, 1937 Savannah, Fla. & West. 5s, 1934 Savannah, Fla. & West. 6s, 1934 Savannah & Statesboro 1st 5s, 1953 . Savannah Elec. 1st Cons. 5s, 1952 Savannah Gas 1st 5s^ 1923 Sawyer, Massey Co. 1st 6s, 1927 Sayre Electric 1st 6s, 1947 Schenectady & Duanes. 1st 6s, 1924 Schenectady Ry. 1st 41/38, 1941 Schenectady Ry. Cons. 41/38, 1953 Schuylkill River, East Eide 4s, 1925 Schuylkill Trac. 1st 5s, 1943 Schwarz. & Sulzb. Co. Deb. 6s, 1916 Scioto Valley & N. E. 1st 4s, 1989 Scioto Valley Traction 5s, 1923 Scranton & Carb. Trac. 1st 68, 1923 Scranton & Pittston 6s, 1923 Scranton Elec. 1st & Ref. 5s, 1937 Scranton Gas & Water Deb. 58, 1935 Scranton Gas & Water 1st 5s, 1923 •Quotation nearest March 1, 1913. No quotation on that date. 1137 High Low Bid Asked 104 106 4.45% basis 1051/3 1031/4 971/3 981/3 102 104 971/2 981/4 1221/8 95% 97 91 *102i/3 80 82 *5i/2% basis *91 98 94 95 83 843/8 88 91 *95 921/3 96 95 108 111% 90 92 931/3 102 1041/8 94% 951/4 85 1011/3 1021/3 93 94 1001/3 90 *90 101 IO6I/3 . 981/4 981/3 100 *100i/3 971/3 101 1061/8 1121/3 118% 1231/4 90 74 76 103 105 1 101 *93i/ 5 95 1131/3 114% 103 103% 105 __ 99% 87 9878 991/4 *93 99 1001/3 105 1071/3 105 1071/3 1011/3 1031/, 102 1031/3 103 104 High Low Bid Asked Scranton Gas & Water Deb. 5s, 1939 _ _- 1021/2 103 Scranton Ry. 1st 5s, 1932 __ — 991/2 101 Scranton Ry. Gen. 5s, 1920 »_ — 961/2 98 Scranton Ry. 5s, 1935 __ — 93 95 Scranton Traction 1st 6s, 1932 -_ >_ 110 112 Scullin, Gallagher Ir. & Steel 58, 1913-25 __ __ __ 100 Sea Beach Ry. 1st 48, 1916 — — 92 95 Seaboard & Roanoke 1st 5s, 1926 — - — — 106% Seaboard & Roanoke Deb. 6s, 1916 >_ __ 102% 105 Seaboard Air Line Ry. — 4s, 1950 _- — 85 861/8 "Stpd." 1950 — — __ 85 Adj. 5s, 1949 711/a 7IV2 Ref. 48, 1959 __ _. 77 771/3 «C" 41/2S, 1913 -_ __ 5-4%% basis *T)" 5s, 1914 — >_ 51/8-47/8% basis «E" 5s, 1914 -_ __ 51/8-47/8% basis «F" 58, 1915 — — 5-4%% basis «G" 5s, 1916 — ._ 51/8-4%% basis **H" 5s, 1916 _- __ 51/8-4%% basis *T' 5s, 1917 — -_ 51/8-4%% basis "J" 5s, 1917 — __ 51/8-47/8% basis **K" 5s, 1917 — __ 51/8-4%% basis **N" 41/28, 1921 -_ __ 51/8-47/8% basis 41/2S, 1923 >- __ 51/8-47/8% basis 5% Notes, 1916 — — 98I/2 98% Equip. 41/2S, 1922 — — 6-4%% basis Equip. 5s, 1919 __ __ 5-4%% basis Seacoast R. R. of N. J. 5s, 1948 — __ 105 108 Seattle Electric 1st 5s, 1930 — — 103 Seattle Electric Cons. & Ref. 5s, 1929 >_ -_ 98 100 Seattle, Everett Trac. 1st 5s, 1939 __ — 97 99 Seattle Lighting 1st 5s, 1944 — __ 102 Seattle Lighting Ref. 58, 1949 __ — 95 96i/a Seattle Lighting deb. 6s, 1920 __ — — '100 Seattle Ry. 58, 1921 — — 100 102 Second Ave. R. R. (N. Y.) 5s, 1948 __ „ 25 36 Second Ave. R. R. (N. Y.) Rec. ctfs. 5s, 1913 __ __ 991/2 100 Second Ave. Trac. 5s, 1934 — — 100% lOlVa Second Ave. Trac. 5s, 1933 __ -_ 103 103% Securities Co., N. Y. Cns. 4s >_ __ 59 61 Shamokin, Sun. & LewVg. 2nd 6s, 1925 __ — 110 Shamon Arizona Ry. 1st 68, 1919 — __ 93 95 Sharon & New Castle 1st 5s, 1931 — — 97% — Shawinigan Wtr. Pr. 1st Cons. 5s, 1934 __ __ — 103% Sheboyan Ry. & Elec. Ref. & Imp. 5s, 1926 __ — — 99 Sheldon Axle Ist 5s, 1930 — __ 94 97% Sheldon Axle 1st 6s, 1921 — — 99 101 Sherbrooke Ry. & Pow. Cons. 1st 5s, 1940 __ — — 95 Sher., Shreveport & So. 1st 58, 1943 — — — 102 Sherwin-Williams 6s, 1949 — — — " •100 Shreveport Bridge & Term. 5s, 1955 — — 93 96 Shreveport Gas & Elec. 58, 1922 __ — '95 Sibley Mfg. 1st 5s, 1922 __ — 90 95 Sierra & S. F. Pow. 1st 5a, 1949 ^- — 93 94% Sierra & S. F. Pow. 2d "A" 68, 1949 __ — 84 86 Sierra & S. F. Pow. 2d "B" 5s, 1949 — — 45 50 Sierra Ry. of Cal. 6s, 1937 — — 100 Silver Spgs., Ocala & Gulf 4s, 1918 __ — 97% 100 'Quotation nearest March 1, 1913. No Quotation ou that date. 1138 High Low Bid Asked Simpson Realty 6s, 1932 — — 97 100 Simpson Secnr. 63, 1929 — ' — 95 Sioux City & Pac. 31/28, 1936 - — 85% __ Sioux City Service 1st Ref. 5s, 1928 — — 96 99 Sioux City Stk. Yds. 1st 5s, 1930 — — — 100 Sioux City Trac. 1st 5s, 1919 — _- — 100 Sioux Falls Lt. & Pow. Ist 6s, 1914-26 __ __ *90 Slate Belt & Elee. Ry. 2nd 4s, 1942 — — — *55 Sloss Iron & Steel 1st 6s, 1920 . — — 104% lOSVa Slo^s Iron & Steel Cons. 41/28, 1918 — __ 94 95 Smith (C. A.) Timber 1st 68, 1927 — — 6% basis Sortus Bay & Southern 1st 5s, 1924 __ — 95 Somerset Coal 5s, 1913-18 — — — *100iA Somerset Hotel Tr. 4s, 1921 — — — 100 Somerset Lighting 1st 5s, 1939 — — — *101 Somerset Ry. 1st 4s, 1955—1 _ — — — 95 Somerset Union & Middlesex Ltg. 4s, 1943__ „ — 79 South & North Alabama Cons. 5s, 1936 — — -* IIO14 South Bend & Mishawaka Gas Cons. 5s, 1926_ _- „ 9414 98 So. Bound & So. Mich. 5s, 1927 — — — 97 South Bend Fuel & Gas 6s, 1920 „ — — *99% South Bound 1st 5s, 1941 -_ __ 107 IO814 So. Caro. & Ga. 1st 5s, 1919 — ._ 100 1021/4 South Caro. Lt., Pr. & Ry. Ist 5s, 1937 — — — 92i/a So. Cov. & Cin. cons. 6s, 1932 __ — 115 125 South Dakota Cent. Ry. 5s, 1927 — — — *97 South Ferry 1st 5s, 1919 — — 971/2 — South Iron & Steel 4-5s, 1929 — — — 15 South Jersey Gas, Elec. & Trac. 5s, 1953 __ __ 99 99% South Pac. Coast Ist 4s, 1937 — — 91 South Platte Canal & Res. 5s, 1923 __ — 89l^ 90 South Shore & Boston 5s, 1919 — — 99 IOI1/3 South Shore Gas & El. Gen. 5s, 1933 „ __ *91i/2 — South "Side Elevated Ry. 41/2S, 1924 „ — 92 931/2 So. Bell T. & T. 5s, 1941 lOOi/g lOOi/g Southern Boulevard 5s, 1945 __ __ 88 93 Southern Cal. Ed. Gen. 5s, 1939 „ >- 96 98 Southern Cal. Gas 1st 58, 1950 __ __ — *101 Southern Counties Gas 1st 6s, 1941 — — ' — •lOO Southern Elec. 5s, 1916 — .. IOO1/2 101 South. Heat, Lt. & P. of Pitts. 5s, 1949 — — *98 South. Improvement 5s, 1941 *85 Southern Ind. Pow. 1st 6s, 1931 __ __ __ 101 Southern Indiana 1st 4s, 1951 __ __ 76I/2 79 Southern Light & Trac. 5s, 1949 __ „ 93 97 Southern N. E. Teleph. 1st 5s, 1948 — — 112 Southern Ohio Trac. 5s, 1920 *93% *93% Southern Pacific Co. — Ref. 48, 1955 93 93 ._ ,— Conv. 4s, 1929 90% 991/3 Brch. Ry. of Cal. 6s, 1937 — — 124 126 R. R. of Cal. 53, 1937 — — — 112% Cen. Pac. 4s, 1949 __ — 94% 951/2 S. F. Term. 4s, 1950 __ — — 881/2 Southern Power 1st 5s, 1930 >_ __ 99 IOOI/2 Southern Railway — 5% Notes, 1916 __ — 99% 99% Equip. 41/28, 1913 — — 5.4%% basis *T." Equip. 41/2S, 1921 — — 5.4%% basis •Quotation nearest March 1, 1913. No quotation on that date. 1139 High Low Bid Asked «N" Equip. 41/28, 1920 __ __ 5.43/4% basis Aiken Br. 1st 4s, 1998 _. __ 5.4%% basis "K" Equip. 4s, 1915 __ ._ 5.43/4% basis 1st Con. 5s, 1994 105i/g IO51/2 Genl. "A" 48, 1956 — __ TTS/g 773^ Memp. Div. 1st 5s, 1996 __ __ 107 107% St. Louis Div. Ist 4s, 1951 __ __ __ S6% Cons. 5s, 1944 ^ __ __ *103 East Tenn. Div. 5s, 1938 __ __ *103% __ M. & O. 5s, 1938 — — *843^ __ 6s, 1915 — — — 1011/2 1031/2 Southern Sierra Pow. 1st 68, 1936 — __ 98 100 Southern Timber 1st 6s, 1913-15 — — __ *100 Southern Traction 1st & Coll. Tr. 5s, 1950— „ — 86 86I/2 Southern Wise. Pow. 1st 5s, 1938 __ __ __ 961/2 Southwest Missouri El. Ry. Ref. 5s, 1923 __ __ 96 100 Southwest Missouri R. R. Gen. 5s, 1931 __ __ 91 93 Southw. Coal & Imp. 1st 6s, 1929 __ __ 102 Southw. Gas & El. 1st & Ref. 5s, 1932 — — 93 931/2 Span.-Amer. Iron 6s, 1927 — — IOI14 IOII/2 Spanish Riv. Pulp & Pap. Mills 6s, 1931 __ __ 9i% 95 Spartansburg Un. & Columbia 4s, 1995 __ __ *83 Spokane & Inland Empire 1st Ref. 5s, 1926— — — 97 99 Spokane Falls & North. 1st 6s, 1939 „ __ 107 Spokane Intern'l. 1st 5s, 1955 __ __ 100 103 Spokane Trac. 1st 5s, 1925 __ __ *98i/3 __ Spring Brook Water 5s, 1926 __ __ 102 105 Spring Riv. Pow. 1st 5s, 1930 __ __ 92 Spring Riv. Pow. 1st 5s, 1937 __ „ *92 Spring Valley Water Co. Genl. Mtg. 4s, 1923. __ __ 931/2 — Springfield & Duanesburg R. R. 1st 6s. 1924__ __ __ __ *115i/2 Springfield Lt., Ht. & Pr. 1st 58, 1929 __ __ 94 97 Springfield (111.) Ry. & Lt. Coll. Tr. 5s, 1933__ __ __ 91 95 Springfield (Mo.) Ry. & Lt. 1st 5s, 1926 __ __ 94 96 Springfield (Mo.) Water 1st 58, 1936 __ __ *88 Springfield (Pa.) Water Cons. 58, 1926 __ __ — •96 Springfield (Vt.) Water Works 3s, 1930 — — *87i4 __ Standard Chain 1st 6s, 1920 __ __ *92 Standard Cordage 1st 5s, 1931 __ __ 10 I21/2 Standard Cordage Adj. 58, 1931 __ __ 12 Stand. Gas & Elec. Conv. 6s, 1926 __ __ 99 100 Stand. Gas Lt. 1st 5s, 1930 __ — IO51/4 IO53/4 Standard Ideal, Ltd. 1st 6s, 1941 __ __ __ *95 Standard Milling 5s, 1930 __ __ 88I/2 89 Standard Oilcloth 6% Notes, 1913-18 100 100 Standard Sanitary Mfg. Deb. 6s, 1920 „ — *98 Standard Steels Works 58, 1928 __ __ IO21/2 — Stanfields, Ltd. Ist 6s, 1931 __ — *5%% basis Stark Elec. Ry. 5s, 1928 *97 Stark-Tus. Brew. 68, 1930 75 State & Lake Bldg. 6s, 1916-22 _. __ *98 State Line & Sullivan 41/28, 1929 __ — 98 Staten Island Ry. 1st 41/2S, 1943 __ — 91 Statlcr Co. 1st 6s, 1931 __ __ __ *100 Bteel Co. of Canada Ist & Coll. 6s, 1940 — — — *99i/2 Steel Co. of Canada 5% Notes, 1915-17 — — *6i/2% basis Steelton Home Gas 5s, 1925 — — *100 *103 Steinway Ry. 1st 6s, 1922 — — 100 102 Stephenville, N. & S. Texas 5s, 1940 — — — 971/2 •Quotation nearest March 1, 1913. No (iiiotatlon on that date. 1140 High Low Bid Asked Steub. & East Liv. R. & L. 1st 5s, 1927 — __ 40 Steubenv. & Ind. 1st 5s, 1914 __ __ 100 Steubenv. & Wheel. Trac. 1st 68, 1935 — — — *94y2 Steubenv. Trac & Lt. 5s, 1926 ^ — — „ *88 Stone, Ltd. 1st 6s, 1931 — — *103 Strathmore Paper 1st 5s, 1926 — — — ^lOSi/g Strathmore Paper ^ 1st 5s, 1928 — — — *105% Strathmore Paper 1st 5s, 1930 — — — *106y8 Strathmore Paper 1st 5s, 1932 — — — *106y2 Streator Tel. & Tel. 5s — — *87y3 __ Streets Western Stable-Car Line 1st Equip. 5s, 1913-27 — — 5.30-5.25% basis Struthers Furnace 6s, 1912-26 *100 *100 Studebaker Corp. 5% Notes, 1912-22 — — 5%% basis Sturgis, Goshen & St. L. R. R. 3s, 1989 — _. — 73y3 Suburban Gas Co. 1st 5s, 1952 — — 100 101 Suburb. Rap. Tran. 6s, 1913 — __ 100 Suffolk & Car. Con. 5s, 1952 — — 100 105 Sullivan & Slauson Co. 1st 6s — — *101 Sulzberger Sons & Co. Deb. 6s, 1916 — — 98% 99^4 Summer Street Ry. 1st 6s, 1926 -_ — 113 116 2nd Series 6s, 1937 — — 116 119 Sumter & Wat. Riv. 5s, 1919 __ — 93 Suubury & Lewiston 1st 4s, 1936 __ — 96y3 -_ Sunbury, Hazel. & Wilkes-Barre 1st 5s, 1928— __ __ 101 Suubury, Hazel. & Wilkes-Barre 2nd 6s, 1938 _- — — lisya Sunbury & Lewiston 1st 4s, 1936 __ — 96y2 — Sunday Creek Co. Coll. 5s, 1944 __ __ 62 75 Superior Short Line 1st 5s, 1930 __ „ 109% __ Superior Wtr., Lt. & Pow. 1st 4s, 1931 __ — 81 84 Superior Wtr., Lt. & Pow. Ref. 5s, 1929 __ — — 90 Susq., Blooms. & Ber. 1st 5s, 1952 — — *100 Swift & Co. 1st 5s, 1944 __ „ 99% 100 Symington (T. H.) & Co. Conv. 6s, 1920 — — — 100 Syracuse Gas 5s, 1946 — — lOiyg 102% Syracuse, Lake Shore & Northern 1st 5s, 1947 __ — *96 *97y3 Syracuse Lt. & Pow. Coll. 5s, 1954 __ __ 82y2 85 Syracuse Lighting 1st 5s, 1951 — — — 101 Syracuse Rap. Transit 1st 5s, 1946 — — 101 102y2 Syracuse Rap. Transit 2nd 5s, 1930 __ — 97 99 Tacoma Eastern 1st 5s, 1923 __ __ *10iy2 — Tacoma Gas & Elec. 5s, 1915 __ __ 92 97 Tacoma Gas Lt. Ref. 5s, 1926 __ __ 80 82y2 Tacoma Ry. & Pow. 1st 5s, 1929 __ . __ 98 100 Tacoma Water Supply 1st 5s, 1925 __ __ __ 92 Tampa & Jacksonv. 1st 5s, 1949 __ — 85 95 Tampa Elec. 1st 5s, 1933 __ __ 99 101 Tampa Gas 1st 5s, 1937 — __ 92 96y, Tampa North. 1st 5s, 1936 __ — 81 86 Tarkio Valley 7s, 1920 __ __ 103y8 — Tarrytown W. P. Mam. 5s, 1928 __ — 75 80 Taunton & Brockton St. Ry. 1st 5s, 1917 — — — *100 Taylor Ave. Ry. 6s, 1913 — — 100 lOOy, Taylor-Wharton Ir. & Steel 1st 6s, 1942 — — *99 *101 Taylor's Falls & L. Sup. 6s, 1914 __ „ 102 Telluride Power Co. 1st 6Sj 1923 __ __ *98 Temescal Water 6s, 1921 __ __ 100 Temple Iron 1st & Coll. Tr. 4s, 1952 __ — 104y2 105 'Quotation nearest March 1, 1913. No quotation on that date. 1141 High Low Bid Asked Tern. Coal, Iron & R. R. 5s, 1951 — ._ 100 lOOy, Tern. Coal. Iron & R. R. (Birm. Div.) 6s, 1917 — — 101 103% Tern. Coal, Iron & R. R. (Tenn. Div.) 6s, 1917 — - -_ 101 103% Tennessee Copper 1st 6s, 1913-17 — — 991/2 101 Tennessee Pow. 1st 5s, 1963 — — 81% 821/3 Tenth & 23rd St. Ferry 1st 5s, 1919 — — 55 65 Term. R. A. Ass'n of St. L. Cons. 5s, 1944 __ __ — 1091/^ Term. R. R. Ass'n of St. L. Ref. 4s, 1953 __ >_ — 91 Term. R. R. Ass'n of St. L. 1st 41/2S, 1939 -_ ._ IO214 104 Term. Wharf & R. R. Warehouse 5s, 1928 — __ *97ya — Terre Haute & Ind. 5s, 1925 — — 103 106 Terre Haute & Peoria 1st 5s, 1942 — — 100 Terre Haute Elec. 5s, 1929 __ — 99 102 Terre Haute Indpls. & East Ref. 5s, 1945 — — 971/2 98i/, Terre Haute Trac. & Lt. 1st Cons. 6s, 1944 — — — 98 100 Terre Haute Water Works 41/2S, 1919 — — 93 97 Texarkana Gas & Elec. Ref. & Prior 6s, 1941 __ __ 'lOl Texarkana Gas &. Elec. 1st 5s, 1930 — — *94 *97y, Tex. & New Orl. Cons. 5s, 1943 — — lOOi/g 101 Texas & N. 0., Dallas Div. 1st 4s, 1930 _- — 87 91 Texas & Okla. 1st 5s, 1943 — — lOli/a 102 Texas & Pacific Ry.— 1st 5s, 2000 106l^ 1061A 2nd 5s, 2000 — — 45 (Louis. Div.) 5s, 1931 — — *95 Equip. «A-A" 5s, 1916 - — — *100i/8 — Texas Central 1st 5s, 1923 . — — 98 103 Texas Co. deb. 6s, 1931 — — 991/3 99y8 Tex. Pow. & Lt. 1st 58, 1937 — — 96 98 Texas Trac. 1st 5s, 1937 — — — 96 Third Ave. Ry. Ist Gen. 5s, 1937 : — — IO61/2 107% Third Ave. Ref. 4s, 1916 8II/2 8II/2 Third Ave. Ref. 4s, 1960 8II/2 8I1/3 Thirteenth & 15th Sts. Pass. Ry. 31/2S, 1934-. „ „ *86i/2 „ Thirty-fourth St. Crosstown 1st 5s, 1996 — — 100 Thompson-Conn. Coke 58, 1931 — — *80 *85 Three Rivers Gas Ist 5s, 1936 — — *80 Tidewater Power 1st 5s, 1949 -_ — 94 98 Tiffin Water Works 5s, 1932 — — *100 Tillamook Timber & Logging Serial 6s *100 "100 Tintern Manor Water 5s, 1930 — — *91 Titusville Elec. Trac. 6s, 1913 — — "100 Toledo & Indiana Trac. 1st 5s, 1931 — — 96 99 Toledo & Ohio Central Ry.— Ist 5s, 1935 — — 10614 107 Western Div. 6s, 1935 — — IO61/8 — Gen. 5s, 1935 — — 100 IOI1/3 (St. Mary's Div.) 4s, 1951 — — •87 ^90 Car. Tr. 4s, 1917 — — 614% 4%% Car. Tr. «B" 4s, 1920 — — 51/4% 4%% Toledo & Western Ry. 1st 5s, 1926 — — 68 70 Toledo, B. G. & So. Trac. 5s, 1921 — — — 85 Toledo, Can. Sou. & Det. 1st 4s, 1956 — — 93 Toledo, Fremont & Norwalk 5s, 1920 — — 97 100 Toledo Gas, El. & Ht. Cons. 5s, 1935 — — 61 1/2 65 Toledo Home Tel. 5s, 1922 — — 9I1/2 93 Toledo, Peor. & West. P. L. 31/2S, 1925 — — 83 85 1st 4s, 1950 — — 54 561/2 Toledo, Peoria & Western 1st 48, 1917 — ~ 89 91 'Quotation nearest March 1, 1913. No quotation on that date. 1142 High Low Bid Asked Toledo, Port Clinton & Lakeside 5s, 1928 __ __ *35 Toledo, St. Louis & Western R. R.— Prior Lien 31/38, 1925 . __ __ 83 85 Prior Lien 31/38, 1925 (Reg'd.) __ __ __ 83 4s, 1950 _- __ 64 551/3 Coll. Tr. "A" 4s, 1917 _- _- __ 60 Equip. 41/3S, 1916 __ »_ '100 Toledo Terminal 1st 41/38, 1957 — __ 84 91 Toledo Trac. Lt. &, Pr. 6s, 1918 __ __ 100 lOOy, Tol., Walhoning Vy. & O. 1st "A" 41/38, 1931 __ __ IOOI/3 _. Tol., Walhoning Vy. & O. 1st "B" 41/38, 1933 __ — IOOI/3 __ Tol., Walhoning Vy. & O. lat "C" 4s, 1942— — — 94 98 Tombigbee Valley 1st 58, 1956 __ __ 92 100 Tombigbee Valley Genl. 63, 1935 __ -_ 95 100 Tonopah & Goldfield 1st 68, 1921 __ _. __ *102 Topeka Edison 1st 5s, 1930 __ __ 97 99 Topeka Ry. 5s, 1930 __ __ 97 99 Toronto & York Radial Ry. 5s, 1919 _- __ *100 Toronto, Ham. & Buff. 1st 4s, 1946 __ __ 89 89l^ Toronto, Ham. & Buff. Equip "A" 41/3S, 1923__ *4%% basis — Toronto Paper Mfg. 6s, 1942 __ __ *96 Toronto Ry. 41/3S, 1913-21 »_ __ 95 Torrington Co. 1st 5s, 1918 _- __ 100 Trenton Gas & Elec. 1st Gen. 5s, 1949 __ __ IO31/3 __ Trenton Pass. Ry. 63, 1931 __ __ 113 114 Trenton, Penn. & Hop. 5a, 1943 _> __ 96 Trenton St. Ry. Cons. 5s, 1938 __ __ 95 100 Trenton St. Ry. Gen. 6s, 1941 __ __ *99 Tri City Ry. & Lt. 58, 1923 97% 97% Tri City Ry. & Lt. Ref. 5s, 1930 __ __ *92l^ *95 Trinidad Elec. 1st 5s, 1931 __ __ __ *92ya Troy & Boston 78, 1924____ __ ._ 120 123 Troy & W. Troy Bridge 5s, 1915 __ __ 101 103 Troy City Ry. 5s, 1942 __ ._ 104 106 Troy Gas 2nd 68, 1923 108 110 Troy Gas Cons. 58, 1939 __ — 106 108 Trumbull Pub. Serv. Ist 6s, 1929 — __ 100 101 Tuckerton R. R. 1st 5s, 1930 __ __ — 100 Tulsa (Okla.) Corp. 1st 5s, 1932 __ >_ 92 95 Turner (J. Sp.) Co. Deb. 63, 1926 __ — *81 *82i/a Twenty-eighth & 29th St. 1st 5s, 1996 — >_ — 20 Twin City Teleph. 1st 5s, 1912-26 __ __ *92 Twin Falls, North Side Land & Water 1st 68, 1912-20 _. __ __ *100 Twin Falls, Oakley Land & Wat. 6s, 1912-20_- __ __ — *100 Twin Falls Ry. Ist 6s, 1932 *100 •lOO Twin Falls Salmon River Land & Wat. 1st 6s, 1912-20 __ __ >- *100 Twin State G. & E. 1st & Ref. 41/3S, 1926 _. __ „ 74 Ulster & Delaware 1st 5s, 1928 __ __ 103% __ Ulster & Delaware Ref. 48, 1952 — — — 84 Underg'd. Elec. Rys. of Lon. 41/38, 1933 __ 95l^ Underg'd. Elec. Rys. of Lon. 6s, 1948 __ __ 91 95 Union Bag & Pap. 5s, 1930 __ __ 89 Union Depot Cons. 6s, 1918 : _'_ __ IO41/2 IO51/3 Union El. Lt. & Pow. 1st 1932 — -_ 100 IOI1/3 Union El. Lt. & Pow. Ref. & Ext. 53, 1933 __ __ 95 971/4 Union Elevated R. R. Ist 5s, 1945 ._ — '75 *90 •Quotation nearest March 1, 1913. No quotation on that date. 1143 High Low Union Ferry 5s, 1920 Unoin Gas (McK.) 5s, 1929 __ - „ Union Gas (Spok.) 5s, 1935 Union Lt., Ht. & Pr. (Gov.) 1st 4s, 1918 -_ , __ Union Lt., Ht. & Pr. (Fargo) 1st 5s, 1933 Union Oil 5s, 1931 Union Pacific R. R. — Conv. 4s, 1927 941/2 94i^ 4s, 1947 98-78 98% Ist Ref. 4s, 2008 Union Ry. 1st 58, 1942 Union Ry., Gas & El. Coll. 5s, 1939 Union Ry., Gas & El. 5% Notes, 1916 97iA 97^4 Union Steel 1st 5s, 1953 Union St. Ry. (New Bedf.) Cons. 5s, 1914 Union Trae. of Ind. 5s, 1919 Union Trae. of Pitts. 5s, 1997 Union Trae. of (Santa Cruz) 1st 5s, 1935 __ — *95 Union Trae (Indep. & Coff., Kan.) 5s, 1937— *93i4 *93iA Union Transportation 5s, 1923 91 Union Typewriter 5s, 1916 Union Utilities 6s, 1944 . Union Water of Cal. 6s, 1956 Unit. Boxbd. & P. Coll. 6s, 1936 Unit. Boxbd. & P. Gen. 6s, 1936 United Breweries 1st 6s, 1938 *70 *70 United Coal 6% Notes, 1916-35 United Coal 1st 5s, 1955 United Elec. Co. of N. J. 4s, 1949 United Elec, Lt. & Pow. 1st 5s, 1934 United Elec, Lt. & Pow. ref. & ext. 5s, 1933— United Elec, Lt. & Pr. 1st Cons. 41/2S, 1939— United Elec Securities Co. C. T. 5s, 1933-1937 United Elec. Securities Co. C. T. 5s, 1943 *99i/2 *99i/2 United Equities 6% Notes, 1915 *100 *100 United Fruit 41/2*, 1923 United Fruit Deb. 41/2S, 1935 United Fruit Deb. 5s, 1916 United Gas & Elec. Conv. 5% Notes, 1915 United Gas & Elec 5s (Cal.), 1933 United Gas & El. (N. J.) 1st Coll. 5s, 1933 Unit. Gas, EL, Lt. & P. Cons. 5s, 1930 Unit. Ilium. (New Haven) 1st 5s, 1940 United Iron & Steel 5s, 1936 United Kansas Portl. Cement 6s, 1930 United Lead Deb. 5s, 1943 United Light, Ht. & Pr. 1st 5s, 1933 United Light & Pr. 6s, 1914 Unit. Lt. & Rys. 1st & Ref. 5s, 1932 United Missouri River Pr. 6s, 1936 United N. J. R. R. & Canal Co. Gen. 4s, 1944— United N. J. R. R. & Canal Genl. 4s, 1923 Genl. 4s, 1939 1st 31/28, 1951 United Properties Realty 6s, 1916 Unit. Pub. Util. (Del.) 1st Coll. 6s, 1943 '100 United Publishers Coll. 6s, 1930 United R. R. of S. F. 4s, 1937 *QuoUtlon nearest March 1. 1913. No quotation on that date. 1144 Bid . Asked 88 93 *96 •98 931/2 95 *93i/2 *96 871/2 90 931/4 95 104 91 93 104 105 100 101 951/2 — 971/2 931/2 971/2 •98 20 38 ~ 100 "■"* *83 •86 81 82 92% *95 •98 93 931/2 98 100 ~ 951/2 95 ^1003/4 961/2 98 1011/4 100 1011/2 100 93 __ *93i/2 __ *50 *63 __ •94 »_ •991/2 92% *98 99 99 100 99 1001/2 871/2 89 ♦96 •93 •94 621/, 63 High Low Bid Asked United Rys. 4s, 1949 __ __ 74 741/2 United Rys. & Elec. 5% Notes, 1914 __ __ lOli/g 102 Unit. Rys. & EL, Bait., Inc. 4s, 1949 63 63 Unit. R. & E. Bait. 1st Cons. 4s, 1949. __ __ __ 85 Unit. R. & E. Bait., Inc. 5s, 1936 — 871/2 871/2 Unit. Rys., Inc., Ist Lien Coll. 5s, 1926 __ — 76% 761/3 Unit. Rys. of St. L. 1st Gen. 4s, 1934 __ __ 731/2 741/3 U. S. Envelope 1st 5s, 1913-34 __ __ 991/2 IO21/2 U. S. Equipment 6% Notes, 1916 __ __ __ *99i/2 U. S. Finishing 1st 5s, 1919 __ __ 99 102 U. S. Finishing Cons. 5s, 1929 __ — __ 97 U. S. Glass 5s, 1923 __ __ __ *95 U. S. Gypsum 1st 5s, 1922 __ __ 97 98 U. S. Gypsum 6% Notes, 1917 __ __ *97 *99 U. S. Leather, deb. 6s, 1913 __ __ lOOi/g 100% U. S. Long Dist. T. & T. Co. 5s, 1934 __ __ 70 U. S. Mtge. & Trust.— Coll. Tr. "E" 4s, 1917 __ __ __ 100 Coll. Tr. "G" 4s, 1918 __ __ __ 100 Coll. Tr. "H" 4s, 1918 __ __ __ 100 Coll. Tt. «I" 4s, 1919 _. -_ >_ 100 Coll. Tr. "J" 4s, 1919 __ __ __ 100 Coll. Tr. "K" 4s, 1920 __ _. __ 100 U. S. Motor 6s, 1916 __ __ __ *59 U. S. Natural Gas 6s, 1929 _« __ *99i/2 — U. S. Radiator 1st 6s, 1912-27 — „ __ *100 U. S. Realty & Imp. deb. 5s, 1924 __ __ 86 87 U. S. Reduction & Ref. 6s, 1931 __ __ 25 321/2 U. S. Rubber 6s, 1918 __ __ 102% 102% U. S. Smelt 1st 6s, 1922 __ __ __ 50 U. S. Smelt. Refin. & Min. 5% Notes, 1914__ __ __ 99 99% U. S. Steel Coll. Tr. 5s, 1951 __ __ 114 U. S. Steel "S. F. 5s, 1963 100% lOOiA U. S. Telephone 1st 5s, 1919 __ __ __ 90 U. S. Whip 1st 6s, 1923 >_ __ __ *96i/2 United Trac. (Albany) Deb. 41/2S, 1919 __ __ 971/3 981/2 United Trac. (Albany) Cons. 4i/oS, 2004 ... __ 96I/2 971/2 United Traction (Pitts.) 5s, 1997 __ __ 95 96 Unit. Trac. & El. 1st Coll. 5s, 1933 __ __ 100 IO31/2 Unit. Traction R'd'g. 1st Coll. 5s, 1926 __ __ __ 96 United Utilities 1st Coll. Conv. 6s, 1943 __ __ __ 94 United Water & Light Coll. 6s, 1912-25 __ __ „ *100 Universal Crushed Stone Co. 6s, 1922 *100 *100 Upchurch Lumber 1st 6s, 1917 __ __ __ *100 Upper Coos 1st 4s, 1930 __ __ 91 Upper Coos, Ex. 41/2S, 1930 __ __ 97 Upson Nut Co., Serial 6s __ __ *100 Urbana & Champaign Ry., Gas & Elec. 1st 5s, 1917 __ >_ *101 Utah & Northern 5s, 1926 __ __ 103 Utah & Northern 1st ext. 4s, 1933 __ __ 9314 99 Utah Central 1st 4s, 1917 __ -_ *82 Utah Co. Coll. Tr. 6% Notes, 1917 __ __ — IOO1/3 Utah Fuel 5s, 1931 __ __ 85 87 Utah Gas & Coke 1st 5s, 1936 __ __ 91 Utah Light & Pr. Cons. 4s, 1930 __ __ 8O14 821/3 Utah Securities 6% Notes, 1922 __ __ 85% 861/4 Utica & Black River 4s, 1922 __ __ 95 Utica & Mohawk Valley 1st 41/2S, 1941 __ __ 97 981/^ ^Quotation nearest Marcb 1, 1913. No quotation on that date. 1145 High Low Utica Belt Line 1st 6s, 1939 Utica Belt Line 2nd 5s, 1931 Utica, Clinton & Bing. Ss, 1939 Utica Elec, Lt. & P. Ist 5s, 1950 Utica Gas & Elec. Ref. & Ext. 58, 1957 Uxbridge & Blackstone St. Ry. 5s, 1923 Valier-Montana Lt. & Pow. Ser. "B" 6s, 1926. Valley Counties Power Co. 58, 1930 Valpraiso & Northern 6s, 1929 Vandalia Coal 1st 6s, 1930 Vandalia R. R. Ser. "A" 4s, 1955 Vandalia R. R. Ser. "B» 48, 1957 Ventura County Power 1st 68, 1936 Vera Cruz & Pac. 41/28, 1934 Verdigris Val. Ind. & W. 1st 6s, 1926 Vermont Pow. & Ltg. 6s, 1927 Vermont Valley 1st 41/28, 1940 Vicksburg & Meridian 1st 68, 1921 Vicksburg Lt. & Trac. 1st 5s, 1932 Vicksburg Lt. & Trac. Deb. 6s, 1922 Vicksb'g., ShrVt. & Pac. 6s, 1941_- 'lOlVa ~ Vicks., Shreve. & Pac. P. L. 6s, 1915 Victor- Amer. Fuel 1st & ref. 6s, 1940 Victor Fuel 5s, 1953 Virginia & Southw. 5s, 2003 Ist 6s, 1958 Virg.-Car.-Chem. 5s, 1923 Virg. Iron, Coal & Coke 6s, 1949 Virginia Midland Ser. "C" 6s, 1916 Virginia Midland Ser "D" 4s-5s, 1921 Virginia Midland 'Ser. "E" 5s, 1926 Virginia Midland Ser'. "F" 5s, 1931 Virginia Midland Genl. 5s, 1936 Virginia Ry. & Pow. 1st & Ref. 6s, 1934 Virginian Ry. Ser. "A" 6s, 1962 Virginian Ry. Equip. "A" 6s, 1913-18 Wabash-Pitts. Term. 1st 4s, 1954 Wabash-Pitts. Term. 2nd 4s, 1954 Wabash-Pitts. Term. 6% Rec. Ctfs., 1914 *100 *100 Wabash-Pitts. Term. Cent. Tr. Rects Wabash-Pitts. Term. Col. Tr. Ctfs. Dep Wabash R. R.— Omaha Div. 31/28, 1941 Deb. "B" 6s, 1939 Equip. "B" 41/2S, 1914 Equip. "C" 41/2S, 1916 1st 5s, 1939 2nd 5s, 1939 1st Lien Equip. 5s, 1921 1st Lien Term. 4s, 1954 1st Ref. & Ext. 48, 1956 Det. & Chic. Ext'n. 6s, 1941 Tol. & Chic. Div. 48, 1941 Deg Moines Ist 4s, 1939 Wabash River Trac. 6s, 1931 Waccannaw Lumber 6s, 1914-28 *100 "100 Walker Co. Ist 6s, 1916 ^Quotation nearest March 1, 1913. No quotation on that date. 1146 Bid Asked 104 110 102 108 102 103 105 98 100 ~ 100 *40 101 __ *75 100 93% 9iy2 93 100 93 95 97 99 103 105 103 95 ~ 100 103 " 96 100 79% 108 95 95% 96% 97 961/8 971/2 104 103 1031/2 104% 1051/2 94 941/2 98% ~ •100 26 iy4 • 2 241/2 25% 26% 65 108 51/2% basis 51/3% basis 104ys 105 971/2 98% 98 100 80 59% 60 105 107% 80 *77 •79 — ♦97 97 101 High Low Bid Asked Ward Baking 1st 6s, 1937 — — *95 Ward Building Si/gS, 1925 „ __ — 100 Warren R. R. 1st & Ref. Sy^a, 2000 — __ _- *83 Warwick Iron & Steel 6% Notes, 1914___ __ __ *10iyz — Wash., Alex. & Mt. Ver. 5s, 1955 . — „ __ 97 Wash., Arlington & Falls Church 5s, 1958 — __ __ *91 Wash., Bait. & Ann. 58, 1941 87% __ Washington Central Ry. 1st 4s, 1948 __ __ 88 93 Washington County Ry. 1st Si/gS, 1954 __ — 80 83 Washington Gas 5s, 1960 — __ 109 110 Washington Market Co. 5s, 1917-27 *104 Washington Market Co. 5s, 1927-47 *102 Wash. Market Cold. Storage 5s, 1939 *99ya — Wash., No. Car. 1st 6s, 1914 ^ __ __ 101 Wash'gtn., Ohio & W. 1st 4s, 1924 __ __ 93 Washington Ry. & Elee. 4s, 1951 — __ 83 84 Washington Term'l. Ist Zy^a, 1945 _- __ 83% __ Washington Term'l. 1st 4s, 1945 >_ — 97iA — Wash. Wtr. Pow. 1st & Ref. 53, 1939 __ __ 102 104 Wash. W^tr. Pow. Coll. 5s, 1929 — — 102 Watauga Power 1st 6s, 1952 __ __ — 101 Waterbury Lt. & Pow. 5s, 1916 __ __ — *99i/a Waterbury Lt. & Pow. 5s, 1921 _- __ __ 99 Waterford Min. Wells & Northw'n. 5s, 1930— __ __ 100 102 Waterloo, Cedar Falls & No. R. 1st 5s, 1940— — __ 87 89 Waterloo, Cedar Falls & No. Ry. 1st 5s, 1929— — __ *87 Watertown Lt. & Pow. 5s, 1959 — _- *97y2 — Watervliet & Turnpike R. R. 1st 63, 1919 — __ 106 108 Watervliet & Turnpike R. R. 2nd 6s, 1919 — __ 106 108 Weaver (W. T.) Power 5s, 1931 __ ._ __ *98 Webster Coal & Coke Ist 5s, 1942 -_ __ 881/2 91 Welsbaeh Co. 5s, 1930 -_ __ 93 93i/a West End Colliery 5s, 1913 __ __ 96 99 West End St. Ry. 5s, 1932 __ __ — 1051/9 West End St. Ry. 41/28, 1914 __ — 99% 100 West End St. Ry. 41/28, 1923 __ — 98iA 99l^ West End St. Ry. 41/33, 1930 ._ __ 98 99 West End St. Ry. Curr. 4s, 1915 __ -_ 98 98% West End St. Ry. Curr. 4s, 1916 — — 971/2 98% West End St. Ry. Curr. 4s, 1917 — — 97% 98% West End St. Ry. 4s, 1932 __ __ 91% 92% West End Trae. Cons. 5s, 1938 102% 102% West India Elec. 5s, 1928 — __ — *92 West Jersey & Seashore Cons. 4s, 1936 — — 98 99% West Jersey & Seashore Ser. "B" 31/2S, 1936— — _- — 90 West Kentucky Coal 58, 1935 „ __ 72 80 West Koot. Pr. & Lt. 1st 6s, 1940 __ _- — 109 West Liberty Street Ry. 1st 5s, 1930 — __ 95 100 West Penn. Rys. 1st 5s, 1931 101% 101% West Penn. Trac. 1st 58, 1960 — — 96 97 West Phila. Pass. Ry. 2nd 5s, 1926 __ — 101 104 West Sacramento Co. 1st 6s, 1930 — — — *100 West Shore 1st 48, 2361 — — 98 98% West Side Belt 1st 5s, 1937 95 100 West Side Belt 6% Ctfs., 1913 _- _- — "100 West Transit Co. 31/2S, 1923 __ — 89% 92% West. Va. & Pitts. 1st 4s, 1990 — __ 90 West Va. Pulp & P. 58, 1921 ._ ._ *95 West Va. Timber 6s, 1913-22 'lOO •100 'Quotation nearest March 1, 1913. No quotation on that date. 1147 High Low Bid Asked West Va. Trac. & Elec. 5% Notes, 1915 — — *96i/2 __ Westchester Electric 1st 5s, 1943 — __ 96 100 Westchester Lighting 1st 5s, 1950 __ __ — IO41/2 Westchester Lighting 5% Notes, 1920 — — __ *98 Westchester St. Ry. 1st 5s, 1932 — — 76 80 Westerly Light & Pow. 1st 5s, 1937 — __ — 100 Western Canada Fl. Mills 1st 6s, 1928 __ — 103 104 Western Canada Fl. Mills, 1st & ref. 6s, 1931 __ __ 100 101 Western Canada Pow. 5s, 1949 __ — __ *88 Western Elec. 5s, 1922 — — 1021/2 IO21/2 Western Foundry & Metal 7% Notes, 1913 — — — *102 Western Maryland 1st 4s, 1952 — — * — 82 Western Maryland 5% Notes, 1915 „ — 971/2 931/2 Western N. Y. & Penna. 5s, 1937 — __ 106 Western N. Y. & Penna. Gen. 4s, 1943 __ — __ 86 Western N. Y. & Pa., Inc. 5s, 1943 __ — 30 35 Western N. Y. & Pa. Trac. 1st Ref. 5s, 1957_- „ — 93 94 Western Nor. Cars 6s, 1914 __ __ *101l^*1013^ Western Ohio Ry. 5s, 1921 *93i/4 „ Western Pacific 5s, 1933 — — 86 86% Western Penna. 1st 4s, 1928 __ — 981/2 991/2 Western Ry. of Ala. 41/2S, 1918___ __ — 95 Western States, G. & E. 1st & Ref. 5s, 1941__ __ __ 88 Western Telep. & Teleg. Coll. 5s, 1932 „ __ 991/3 991/2 Western Union Tel. 5s, 1938 — — 100% 101% Western Union Tel. Fdg. & R. E. 41/2S, 1950— — — — 95 West. Unit. G. & E. 1st Serial 5s — — *99 *100 West. Unit. G. & E. Deb. Serial 6s __ „ *100 Westingh. Elec. & Mfg. 6% Notes, 1913 __ — IOO1/4 IOO34 Westingh. Elec. & Mfg. 5% Notes, 1915 — __ *100 100% Westinghouse Elec. & Mfg. 5s, 1931 92 92 Westinghouse Elec. & Mfg. 5s, 1917 — — 96^/4 97i/o Westinghouse Machine It & Ref. 6s, 1940 __ __ 83 90 Westinghouse Machine 6% Notes, 1914 — — *84 Whatcom Co. Ry. & Lt. 5s, 1935 __ — 93 95 Wheeling & Lake Erie Ry. — Lake Erie Div. 1st 5s, 1926 — __ — 101 1/2 Wheeling Div. 5s, 1928 __ — 99 Ext. & Impt. 5s, 1930 ._ — — 104l^ 1st 48, 1949 — — 80% 81 Equip. 5s, 1922 — — 98i4 _. 5% Rec. Ctfs., 1913-23 100-96.19 ace. to mat. __ Wheeling Elec. (W. Va.) 1st 58, 1941 „ „ 941/2 96I/2 Wheeling Term. 4s, 1940 — — 88 92 Wheeling Trac. 5s, 1931 __ — 97 99 Whipple Car 1st 6s, 1913-22 *100 *100 Wliipple Car Serial 51/2S, - •lOO White & Black Riv. Val. Ist 5s, 1980 — — — *100i/. White Plains Ltg. 1st 5s, 1938 _. __ *98i/2 — Whittier Home T. &T. Co. 5s, 1929 __ — 68 Wichita Falls & Northwestern Ry. — 1st 5s, 1939 — — "gSi/s'lOO 1st & Ref. 5s, 1940 — — *96 *97i/2 1st 5s, 1925 — — — *96i/2 South. 5s, 1938 ,— — *93 *97 Wichita Natural Gas 1st 6s, 1915 — — *97 Wichita R. R. & Lt. Ref. & Cons. 5s, 1932 — ~ — 99 Wichita Union Term. 1st 41/2S, 1941 — — 99 101 Wilkes-Barre & Eastern Ist 5s, 1942 — — — 98% "Quotation nearest March 1, 1913. No quotation on tbat date. 1148 High Low Wilkes-Barre & Hazelton 1st 5s, 1951 Wilkes-Barre & Wyo. Val. 5s, 1931 Wilkes-Barre & Wyo. Val. 5s, 1925—^ Wilkes-Barre Co. 1st 5s, 1960 Wilkes-Barre, Dal. & Har. Lake 5s, 1938 Wilkes-Barre Gas & Elec. 5s, 1955 Wilkinsburg & E. Pitts. 1st 5s, 1929 Wilkinsburg & Verona St. Ry. 5s, 1931 Williamsburg & Flatbush AYza, 1941 Williamsport & North Br. 1st ^y^s, 1931 Williamsport Gas 1st 5s, 1939 Willimantic Gas & Elec. 5s, 1923 Wilmur & Sioux Falls, 1st 5s, 1938 Wilm. & Chester Trac. 5s, 1918 Wilmington & North. Sk. Trust 4s Wilmington & North. 1st 5s, 1927 Wilmington & North. Genl. 5s, 1933 Wilmington & Weldon Gen. 5s, 1935 Gen. 4s, 1935 Wilmington City El. 1st 5s, 1951 Wilmington Gas 1st & Ref. 5s, 1949 Wilmington Lt. & Pow. 1st 5s, 1960 Winnipeg Elec. Ry. 1st & Ref. 5s, 1935— Winnipeg Terminal 4s, 1939 Winono & Pacific 1st 7s, 1916 Winona & St. Peter. 1st 7s, 1916 Winona Interurban Ry., Goshen 5s, 1925 Winston-Salem Southbound Ry. 5s, 1960 Wisconsin Central Ry. — Sup. & Dul. Div. & Term. 4s, 1936 1st Ref. 4s, 1959 Marsh. & 'S. E. P. M. 4s, 1951 4s, 1949 9014 901/4 Wisconsin Gas & Elec. 1st 5s, 1952 Wisconsin, Minn. & Pac. 1st 4s, 1950 Wisconsin Pub. Serv. 1st & Ref. 5s, 1943 Wisconsin Riv. Pow. 1st 5s, 1941 Wisconsin Trac, Lt., Ht. & P. 1st 5s, 1931 Wladikawkas Ry. 4s, 1957 Woodward Iron 1st 5s, 1952 Worcester & Clinton Ry. 1st 5s, 1919 Worcester & Conn., Eastern 1st 4y2S, 1943 Worcester & Marlborough St. Ry. 1st 5s, 1917 Worcester & Southridge St. Ry. 41/2S, 1922— Worcester & Web. 1st 5s, 1919 Worcester Cons. St. Ry, 4y2S, 1920 Worcester Cons. St. Ry. 1st Ref. 41/2S, 1930__ Worcester Cons. St. Ry. Deb. 5s, 1927 Worcester, Nashua. & Roch. 4s, 1930 Worcester, Nashua. & Roch. 4s, 1934 Wright Bldg. 5s, 1931 Yadkin Riv. Pow. 1st 5s, 1941 Yale & Towne Mfg. 5s, 1920 Yonkers Ry. 1st 5s, 1946 York Haven Wtr. & Pow. 1st 5s, 1951 York Haven Wtr. & Pow. Cons. 5s, 1957 York Rys. 1st & Coll. 5s, 1937 Yosemite Valley R. R. 5s, 1936 •Quotation nearest March 1, 1913. No quotation on that date. 1149 Bid . Askeil 66 67% 102 103 100 103 921/2 95 100 1021/3 102 103 1003/4 103 101 92 95 50 60 100 102 109 96 98 95 __ 991/2 107 109 1091/2 110 93 98 100 99 100 841/3 100 102 94 97 IO8I/2 1091/4 IO8I/2 1091/4 *70 *80 ~ 891/2 893/s 89% *89V^ *87 *90 97 99 35 45 95 96 90 99 841/2 90 *96 98 100 __ 98 95 97 96 96 100 103 95 95 971/2 96 — 85 991/2 100 88 95 76 85% 60 65 94 951/2 *90 High Low Yonghiogheny-Mon. Coal 6s, 1913-15 Young Men's Christ. Assoc. (Indpls.) 1st 41/28 *100 *100 Youngstown & Ohio River 1st 5s, 1935 Youngstown & Southern Ry. 1st 5s, 1933 Youngstown, Sharon Ry. 5s, 1931 Youngstown Telephone 1st 6s, 1919 Zanesville Ry., L. & P. 5s, 1924 __ __ 931/2 100 •Quotation nearest March 1, 1913. No quotation on that date. Bid Asked 981/2 ~ 98 100 82 87 100 102 — •99% 1150 Government, State and Municipal Bonds UNITED STATES GOVERNMENT High Low Bid Asked U. S. Cons. Reg. 2s, 1930 __ __ lOOyg 101 U. S. Cons. Coup. 23, 1930 __ _. 100% 101% U. S. Reg. 3s, 1918 __ __ 1021/2 103l^ U. S. Coup. 3s, 1918 __ __ 1021/2 103l^ U. S. Reg. 4s, 1925 __ __ II31/2 114 U. S. Coup. 4s, 1925 __ __ 113% 114% U. S. Pan. Can. 2s, 1936 „ __ 100% 101 U. S. Pan. Can. 3s, 1961 -_ __ 1023/8 103 U. S. Pan. Can. 2s, 1938 __ __ 100% 101 ALABAMA Alabama, Renewal CI. C. 4s, 1956 __ __ 103 104 Alabama, Curr. Fdg. 4s, 1920 __ __ 100 101 Alabama, Renewal 31/2S, 1956 93 96 Attalla (Ala.) 6s, 1922 __ __ __ '100 Bessemer (Ala.) 5s, 1931 __ __ __ *102i/2 Birmingham (Ala.) Ref. 6s, 1923 __ __ 105 108 Birmingham (Ala.) Imp. 5s, 1921 __ 102 106 Birmingham (Ala.) School 5s, 1924 __ __ 102 106 Birmingham (Ala.) Sewer 5s, 1938 __ __ 103 106 Birmingham (Ala.) Fund 5s, 1941 __ __ 104 106 Decatur (Ala.) 6s, 1923 __ __ _- *100 Geneva (Ala.) 5s, 1930 __ __ __ *97 Jasper (Ala.) Sewer 8s, 1923 __ __ __ *106 Jefferson Co. (Ala.) 6s, 1921 __ __ 4%-i/2% basis Jefferson Co. (Ala.) 6s, 1917 — __ 4%-i/2% basis Jefferson Co. (Ala.) 41/2S, 1931 __ __ 100 IO21/3 Jefferson Co. (Ala.) Hosp. 41/2S, 1963 __ __ 101 103 Jefferson Co. (Ala.) 5s, 1920 __ __ 41/2% basis Madison Co. (Ala.) 5s, 1919 __ __ 4%-i/2% basis Madison Co. (Ala.) 5s, 1929 __ __ 4%-i/2% basis Montgomery (Ala.) 6s, 1924 __ ._ 4%-i/2% basis Montgomery (Ala.) 6s, 1921 __ __ 4%-i/2% basis Montgomery (Ala.) St. Pav. 5s, 1921 ._ -._4.80-.60% basis Montgomery (Ala.) Fdg. 5s, 1940 — — 102 105 Montgomery (Ala.) Wtr. 41/2S, 1928 __ __ . __ 99l^ Montgomery (Ala.) S. W. W. & S. 41/2 s, 1944_ __ __ 97 99 Mobile (Ala.) 5s, 1914-19 __ __ 99 100 Mobile (Ala.) Ref. 41/2S, 1937 __ _- 95 100 Mobile (Ala.) Wtr. & Sr. 41/2S, 1939 >_ — 95 100 Mobile (Ala.) Impot. 4s, 1921 __ __ 90 95 Mobile Co. (Ala.) Ref. 5s, 1928 __ __ 104 106 Mobile Co. (Ala.) Ref. 5s, 1931 __ __ 104 108 Mobile Co. (Ala.) Road 5s, 1932 4.80-.60% basis ^Quotation nearest March 1, 1913. No quotation on that date. 1151 ALABAMA (Continued). High Mobile Co. (Ala.) Jail 4s, 1926 Montgomery Co. (Ala.) 5s, 1935 Prattville (Ala.) 6s, 1923 Selma (Ala.) Wtr. 5s, 1927 ARIZONA Arizona, Fund 5s, 1942 Arizona, Ref. 41/28, 1928 Mohave County (Ariz.) 5s, 1928-38 Phoenix Sch. (Ariz.) 5s, 1933 Tucson (Ariz.) Wtr. 5s, 1950 Tucson (Ariz.) W. W. Mch. 41/28, 1938 Prescott (Ariz.) 41/2S, 1948 Prescott (Ariz.) 5s, 1955 ARKANSAS Arkansas Co. (Ark.) 6s, 1918-32-—^ Cypress Creek (Ark.) 51/2S. 1930-35 Danville Sch. (Ark.) 6s, 1918 Dead Timber (Ark.) 6s, 1927-32 Ft. Smith (Ark.) Wtr. 5s, 1918-26 Ft. Smith (Ark.) Sewer 5s, 1926 Ft. Smith (Ark.) School 5s, 1917-33 Green & Lawrence Cos. (Ark.) 6s, 1916-31 Heber Springs (Ark.) Sch. 58, 1942 Jefferson Co. (Ark.) 6s, 1925-38 Little Rock (Ark.) 5s, 1913-21 Miller Co. (Ark.) 6s, 1931 Mississippi Co. (Ark.) 6s, 1920-27 Mississippi Co. (Ark.) 51/2S, 1929-31 Poinsett Co. (Ark.) 6s, 1922-36 St. Francis (Ark.) Levee Dist. 6s, 1943 St. Francis (Ark.) Levee Dist. 6s, 1947 St. Francis (Ark.) Levee Dist. 5s, 1949 St. Francis (Ark.) Levee Dist. 58, 1939 White & Cache River (Ark.) 6s, 1922 White River (Ark.) 6s, 1929-33 Woodruff Co. (Ark.) Rd. 6s, 1923-33 Wynne (Ark.) Sewer, Wtr. & Lt. sy^s, 1914-32 Low Bid Asked 92 95 103 105 __ *107% 100 102 99 100 101 102l^ __ *103.86 _- *105 100 101 4%% basis 100 100 51/2% *5.30% •51/2% *43/4% *5y2% •5%% *5i/2% *5.40% *5y8% 105 105 97 *5y"% *5.40% '51/4% basis basis *105 basis *100 *100 basis basis •98 basis *100 *ioiy8 basis basis basis 108 108 99 •981/2 basis *100 basis CALIFORNIA California, Harb. Imp. 48, 1985 California, High. 4s, 1919-20 Alameda (Cal.) 4s, 1913-41 Alameda (Cal.) Mun. Imp. 41/2S, 1948 Bakersfield (Cal.) 5s, 1952 Burlingame (Cal.) Sch. 5s, 1930-41 Colusa Co. (Cal.) Sch. 5s Fullerton (Cal.) Sewer 7s Glendale (Cal.) 5s, 1914-53 Inglewood (Cal.) 5s, 1913-32 Los Angeles (Cal.) 41/33, 1913-35 Los Angeles (Cal.) O. R. 41/2S, 1914-47 •Quotation nearest March 1, 1913. No quotation on that date. 1152 4% 4% 4.45% 4.50% 4.60%, ^4.60%, - *4.70%, - *4.70% .4.60-.50%, .4.60-.50% basis basis basis basis basis basis *101 •101 basis basis basis basis CALIFORNIA (Continued). High Low Bid Asked Los Angeles (Cal.) Harb. imp. 41/38, 1913-51___ __ __4.60-.50% basis Los Angeles (Cal.) Elec. pit. 41/28, 1917-51 __ __4.60-.50% basis Los Angeles (Cal.) Wtr. 4s, 1913-45 __ __4.60-.50% basis Los Angeles (Cal.) 4s, 1913-30 __ __4.60-.50% basis Los Angeles (Cal.) Wtr. 3%s, 1913-41 __ __4.60-.50% basis Los Angeles (Cal.) Sch. 3%8, 1913-44 __ __4.60-.50% basis Los Angeles (Cal.) Water 41/3S, 1923 __ __ — *100.86 Los Angeles (Cal.) Ser. 334s, 1932-33 __ __ *4 1/2% basis Los Angeles Co. (Cal.) 41/2S, 1915-49 ._ __ 4.30% basis Los Angeles Co. (Cal.) 41/2S, 1941 __ __ __ *100 Los Angeles Co. (Cal.) 41/2S, 1942 — — __ *102i/2 Los Angeles (Cal.) Sch. 4s, 1932-45 __ „ *4.40% basis Los Angeles Co. (Cal.) Sch. 41/2 s, 1944-48 __ __ __ *100 Los Angeles Co. (Cal.) 41/28, 1938-49 __ __ *4i/2% basis Los Angeles Co. (Cal.) Sch. 41/3S, 1930 __ __ __ *102.39 Merced Co. (Cal.) 4s, 1913-16 __ __ 4.30% basis Merced Co. (Cal.) 68 __ __ *100 104 New Home (Cal.) Sch. 5s, 1914-22 __ __ *4.80% basis Newport (Cal.) Sch. 5s, 1934-39 __ __ *4.60% basis Oakland (Cal.) S. D. 48, 1913-44 __ __ 4.45% basis Oakland (Cal.) 41/38, 1935 __ __ __ *101% Oakland Co. (Cal.) 41/38, 1915-47 — __ 4.45% basis Oakland Co. (Cal.) Sch. & C. 41/2S, 1913-51__ __ __ 4.45% basis Ocean side- Carlsbad (Cal.) Sch. 5s, 1913-31 __ __ *4.70% basis Pasadena (Cal.) 4s, 1941-42 __ __ 41/3% basis Pasadena (Cal.) Wtr. 41/38, 1917-36 __ __ 41/3% basis Pasadena (Cal.) Sch. Dis. 41/3S, 1913-22 __ __ 41/3% basis Sacramento (Cal.) 4s, 1915-45 __ __ 4.40% basis Sacramento Co. (Cal.) 41/2S, 1917-46 __ __ 4.40% basis San Diego (Cal.) 41/38, 1913-41 __ __ 41/2% basis San Diego (Cal.) Wh. & Har. 41/oS, 1914-52___ __ __ 4%% basis San Diego (Cal.) Sch. 5s, 1914-21 __ __ *4.45% basis San Diego (Cal.) 41/3 s, 1944-47 __ __' *4.60% basis San Francisco (Cal.) 5s, 1913-55 __ __4.60-.40% basis San Francisco (Cal.) 31/3S, 1913-44 __ __4.60-.40% basis San Francisco (Cal.) Sch. 31/2S, 1919 __ __ *4.45% basis San Francisco (Cal.) 41/2S, 1913-34 __ __ __ *100 San Francisco (Cal.) 5s, 1940__. __ __ __ *107y8 San Francisco (Cal.) 5s, 1918-39 __ __ *4i/2% basis Santa Monica (Cal.) Sch. 5s, 1939-52 __ __ *4.60% basis Stanislus Co. (Cal.) 5s __ __ __ *101 Suisun (Cal.) Water 5s, 1941-53 __ __ *4.70% basis San Joaquin Co. (Cal.) 5s, 1913-49 __ __ 4.30% basis San Jose (Cal.) 48, 1913-46 __ __ 4.45% basis Santa Barbara (Cal.) 5s, 1913-41 __ __ 41/2% basis Santa Barbara (Cal.) 41/38, 1943 __ __ 41/3% basis Stockton (Cal.) S. D. 5s, 1913-21 __ — 41/3% basis Tehama Co. (Cal.) Sch. 6s __ __ __ *102 Venice (Cal.) Sch. 6s, 1918-47 __ __ *4.60% basis West Glendale (Cal.) Sch. 5s , __ __ *4.45% basis CANADA (DOMINION OF) Antigonish (N. S.) 41/38, 1921 __ __ __ *98.35 Antigonish (N. S.) 41/3S, 1940 _> __ __ *96i/2 Bassano (Alberta) Wtr. & 'Sewer 5s, 1914-43-_ __ __ *5% basis Black Lake (Que.) 5s, 1938 __ __ __ *96y2 *Quotatlon nearest March 1, 1913. No quotation on that date. 1153 CANADA, DOMINION OP (Continued). High Low Bid Asked Bolivia Ry. 1st 5s, 1927 __ — 94 Brandon (Man.) 41/2S, 1942 __ __ __ *92.33 Brantford (Ont.) 4s, 1934 __ __ *^%% basis Bridgewater (N". S.) 5s, 1954 __ __ __ *100 Brockville (Ont.) 41/28, 1931 __ _. *4i/2% basis Calgary (Alberta) 41/2S, 1926 — — *5% basis Calgary (Alberta) Sch. 4y2S, 1947-49 _ *^7s% basis Calgary (Alberta) 41/28, 1919-52 __ __ *4t%% basis Calgary (Alberta) Sch. 41/2S, 1914-53 __ „ *4%% basis Campbellton (N. B.) 4s, 1934 __ _- *5% basis Canada (Dom. of) Ref. 31/28, 1913 __ >_ 98 Cartierville (Que.) 5s, 1942 _- __ __ *98.13 Castor (Alberta) 51/38, 1913-32 „ __ __ *95.97 Cobalt (Ont.) 6s, 1914 __ __ *6% basis Coldstream (B. C.) 5s, 1940 __ __ — *100 Edmonton (Alberta) 41/2S, 1913-21 __ __ __ *97.79 Edmonton (Alberta) 5s, 1933 __ __ *5% basis Edmonton (Alberta) 41/2S, 1944-45 __ __ *5i/2% basis Edmonton (Alberta) 41/2S, 1931-51 __ __ *4.06% basis Edmonton (Alberta) 5s, 1953™ __ — — *96.65 Fernie (B. C.) 5s, 1940 __ — *5i/2% basis Ft. William (Ont.) 5s, 1933 __ _> — *100 Gait (Can.) 41/2S, 1931 __ __ 4%% basis Gait (Can.) El. Pr. 41/2S, 1931 __ __ 4%% basis Glace Bay (N. S.) 41/38, 1933 __ __ *5i/2% basis Gravenhurst (Ont.) 5s, 1939 __ __ *5i/8% basis Guelph (Ont.) 5s, 1917 — __ 5% basis Guelph (Ont.) Cons. 58, 1920 — — 5% basis Halifax (N. S.) 4s, 1945 „ __ 4%% basis Halifax (N. S.) 31/2S, 1920 __ — 5% basis Hamilton (Ont.) 48, 1920 __ „ 4%% basis Hamilton (Ont.) 4s, 1932 — __4.30-.20% basis Manitoba (Prov. of) 4s, 1930 __ — 97 98 Manitoba (Prov. of) Drnge. 4s, 1929 __ __ 97 98 Maisonneuve (Que.) 414s, 1951 — — 4%% basis Medicini Hat (Alberta) 5s, 1942 — __ *5.40% basis Medicini Hat (Alberta) 58, 1942 __ — — *94.13 Mexico (U. S. of) External Loan of 1899 58__ __ __ 92 93 Mexico (U. S. of) 4s, 1954 __ — — 84 Montcalm (Que.) 41/28, 1952 __ __ — *97i/4 Montreal (Que.) 48, 1925 __ _- 41/2% basis Montreal (Que.) 4s, 1927 _- — 4%% basis Montreal (Que.) 4s, 1933 — — 41/2% basis Montreal (Que.) 4s, 1944 __ — 41/2% basis Montreal (Que.) Ref. 31/2S, 1939 __ — 41/2% basis Montreal (Que.) School 4s, 1942 __ ._ — *90.44 Moose Jaw (Sask.) School 41/2S, 1913-28 __ — '51/2% basis Moose Jaw (Sask.) 58, 1933 __ __ — *97.53 Manaimo (B. C.) 5s, 1922 — — — *96.34 Nelson (B. C.) 53, 1923 — — — *94.06 New Brunswick (Prov. of) 31/28, 1933 _. — 92 93 New Brunswick (Prov. of) 31/2S, 1932-36 __ — *4.10% basis New Brunswick (Prov. of) 4s, 1921 __ — 99 100 New Bnmswick (Prov. of) 4s, 1930 _. — 99 100 New Brunswick (Prov. of) 4s, Jan., 1932 — — 99 100 New Brunswick (Prov. of) 3s, 1938 — — *4.10% basis New Brunswick (Prov. of) 4s, 1942 — — "4.40% basis 'Quotation nearest March 1, 1913. No quotation on that date. 1154 CANADA, DOMINION OP (Continuea). High Low Bid Asked New Brunswick (Prov. of) 4s, 1942 __ __ *4.40% basis No. Vancouver (B. C.) 5s, 1929 __ __ *5% basis North Vancouver (B. C.) 5s, 1960 __ __ __ 100 Nova Scotia (Prov. of) 4s, 1919 __ __ 99 100 Nova Scotia (Prov. of) 4s, Jan., 1920 __ __ 99 100 Nova Scotia (Prov. of) 4s, May, 1920 __ __ 99 100 Oak Bay (B. C.) 5s, 1929 __ „ __ *100 Oak Bay (B. C.) 5s, 1922-32 __ __ __ *99 Ontario (Prov. of) SVgS, 1936 __ __ 4.-3.90% basis Ottawa (Ont.) SYzS, 1928 __ __4.50-.30% basis Ottawa (Ont.) 4s, 1932 _> __ __ 95.11 Owen Sound (Ont.) ^%s, 1932 __ __ *5% basis Penticton (B. C.) 5s, 1953 __ __ __ *84.90 Pt. Arthur (Ont.) 53, 1937 __ __ *5% basis Pt. Hawkesbury (N. S.) 5s, 1942 „ __ *5i/8% basis Prince Albert (Sask.) 5s, 1933 -_ ._ *5.40% basis Quebec (Prov. of) stock 3s, 1937 __ __ — *80 Quebec (Prov. of) stock 4s, 1949 __ __ *4.40% basis Quebec City (Que.) 31/28, 1930 __ __ 41/2-14% basis Quebec City (Que.) 41/2 s, 1922 __ __ 41/2-14% basis Quebec City (Que.) 31/28, Jan., 1931 __ __ 41/2-14% basis Quebec City (Que.) 31/2S, Jul., 1931 __ __ 41/2-14%, basis Quebec City (Que.) 31/2 s, 1933 __ __ 41/2-14%, basis Red Deer (Alberta) 5s, 1913-15 __ __ *6% basis Revelstoke (B. C.) 5s, 1927 __ __ __ *95.05 Revelstoke (B. C.) 5s, 1934 __ __ *5i/8%, basis Richmond (B. C.) 41/2S, 1962 __ ._ *5% basis St. Boniface (Man.) 5s, 1932 __ __ __ *100 St. Boniface (Man.) 5s, 1932-42 __ __ __ *100 St. Boniface (Man.) 5s, 1931 __ __ 4%% basis St. Thomas (Ont.) 5s, 1941 __ ._ *5%, basis Sao Paulo 5s, 1919 __ __ 961/2 97 Sorel (Que.) 5s, 1952 __ __ __ *98.95 Spallumcheen (B. C.) 5s, 1941 __ __ *5i/8% basis Sydney Mines (N. S.) 41/2S, 1925 __ __ __ *95 Tokyo (Japan) 5%, Loan of 1912 — __ 86% 8814 Toronto (Ont.) 4s, 1916 __ __ 5% basis Toronto (Ont.) 4s, 1918 __ __ 5% basis Toronto (Ont.) St. Imp. 4s, 1922 -_ __ „ 94% Toronton (Ont.) 31/2S, 1914 __ __ 5% basis Toronto (Ont.) 31/2S, 1944-45 ^- __ __ __ 41/2 Vancouver (B. C.) St. Imp. 4s, 1922 __ — — 92.49 Vancouver (B. C.) St. Imp. 4s, 1927 __ — — 89.76 Vancouver (B.C.) St. Imp. 4s, 1932 __ __ — 87.62 Vancouver (B.C.) 31/2S, 1942 — — ♦4%%o basis VancouverB. C.) 4s, 1943 __ — *4%% basis Vancouver (B. C.) 4s, 1946 __ — *4%% basis Vernon (B. C.) 5s, 1926-36 — — *5i/2% basis Victoria (B. C.) 4s, 1922 __ — — *92.51 Victoria (B. C.) 4s, 1936 — — *4%% basis Victoria (B. C.) 41/2S, 1938 ^ __ — — *96.36 Welland (Ont.) 41/2S, 1939 — — — *92.70 Westmount (Que.) 4s, 1954 _- _« *4.40% basis Winnipeg (Man.) 4i, 1934 _- __ 41/2% basis *Quotation nearest March 1, 1913. No quotation on that date. 1155 CANADA, DOMINION OP (Continued). High Low Bid Asked Winnipeg (Man.) Sch. 31/38, 1948 __ __ *4y2% basis Yorkton (Sask.) 5s, 1913-40 __ __ *6% basis York (Ont.) 5s, 1914-31 __ ._ __ *100 Youville (Que.) school 5s, 1952 — __ — *97.89 COLORADO Colorado 4s, 1922 __ „ 99 100 Colorado 3s, 1929 — __ __ *88.01 Boulder (Colo) 5s, 1926 __ __ lOli/g 1031/2 Boulder (Colo.) Water 41/2S, 1923 __ __ __ *97.90 Colo. Spgs. (Colo.) Ref. 4s, 1929 __ __ 92 95 Colo. Spgs. (Colo.) Wtr. 5s, 1918-28 __ __ __ *101i/2 Cortez (Colo.) Water 6s, 1919-24 __ __ __ *101 Delta Co. (Colo.) Ref. 5s, 1920 __ __ 97 100 Denver City & County (Colo.) 51/38, 1917-27— __ __ *5.10% basis Denver (Colo.) 5s, 1919 __ __ 103 105 Denver (Colo.) S. D. 41/2S, 1917 __ „ 99 100 Denver (Colo.) S. D. 4s, 1922 __ __ 41/2% basis Denver (Colo.) 6s __ «_ __ *101i/2 Denver (Colo.) 51/2S, 1915-16 „ __ *5.40% basis Denver (Colo.) 51/2S, 1927 — — — *100 East Denver (Colo.) 51/2S __ __ __ *100 Grand Jet. (Colo.) 5s, 1926 __ __ 100 IOO1/2 Gunnison Co. (Colo.) 4s, 1919 __ __ 89 93 Gypsum (Colo.) Water 7s, 1922-27 — — — *105.31 Haxtun (Colo.) Water 6s, 10-15 yrs __ __ __ *100 Holyoke (Colo.) Water 6s, 1919-27 — — *5%-6% basis Hotehkiss (Colo.) Water 6s, 1914-19— — „ — *100i/2 Jackson Co. (Colo.) 5s, 10-20 yrs __ __ „ *100 Julesburg (Colo.) Water 68, 1920 __ „ — *100.79 Lake Co. (Colo.) 4s, 1921 „ — 82 86 Las Animas Co. (Colo.) 41/2S, 1931 __ — 98 100 Ouray Co. (Colo.) 48, 1921 __ __ 85 90 Olathe (Colo.) Water 6s, 1921-26 — — — *101 Pueblo (Colo.) 5s, 1918 __ __ 4.60% basis Pueblo (Colo.) Wtr. 41/38, 1914 __ __ 4.60% basis Pueblo Co. (Colo.) 41/2S, 1931 __ — 4.60% basis Pueblo Co. (Colo.) S. D. 41/38, 1932 — — 99 100 Rio Grande Co. (Colo.) 5s, 1919 „ — 96 99 Trinidad (Colo.) Ref. Wtr. 5s, 1932 __ — 971/2 101 Victor (Colo.) 5s, 1916 __ — 85 90 Weld Co. (Colo.) 6s, 1927-42 — — — *107y2 DISTRICT OF COLUMBIA Columbia (Dist. of) Fd. Cur. 3.65s, 1924 — __ 105 107 CONNECTICUT Connecticut 4s, 1936 — __ 3.80% basis Bridgeport (Conn.) 41/38,1918 __ _. 4.21-10% basis Bridgeport (Conn.) 4s, 1919 __ __ 98 Bridgeport (Conn.) 4s, 1920-40 — — *4.07-4y8% basis Bristol (Conn.) Fdg. 4s, 1927 — — 98 Danbury (Conn.) 4s, 1920 __ — 4.20-10% basis 'Quotation nearest March 1, 1913. No quotation on that date. 1156 CONNECTICUT (Continued). High Low Bid Asked Danbury (Conn.) Si/gS, 1941 , __ __ 90 Danbury (Conn.) 31/38, 1933 __ __ __ *90% Danbury (Conn.) 4s, 1935 __ __ *4i4% basis East Hartford (Conn.) 4s, 1924 __ __ 99 East Hartford (Conn.) Fire D., 4s, 1931 __ __ 99 Hartford (Conn.) 4s, 1918 __ __ 100 Hartford (Conn.) Wtr. 4s, 1918 __ __ 100 Hartford (Conn.) 31/28, 1954 __ __ 90 92i/8 Hartford (Conn.) S. D. Ars'l 4s, 1917 _. __ 100 Hartford (Conn.) 2nd 4s, Nor. 1924 __ __ 100 Hartford (Cnn.) 4s, South., 1927 __ __ 100 Hartford (Conn.) 31/2S, South., 1931 __ __ 92 Hartford (Conn.) 31/2S, South., 1955 __ __ 91 Meriden (Conn.) 31/2S, 1917-24 __ __ 4.15% basis Meriden (Conn.) 4s, 1914-18 __ __ 4.15-10% basis Middletown (Conn.) 4s, 1922 __ __ 98 Middletown (Conn.) Seh. 4s, 1915 __ __ 99 100 Middletown (Conn.) 31/2S, 1921 __ __ 93 96 New Britain (Conn.) 4s, 1927 __ __ 98 New Britain (Conn.) Sewer, 31/2S, 1924 __ __ 4.15% basis New Brit. Farm (Conn.) School, 31/2S, 1929— __ __ 4.15-10% basis New Haven (Conn.) 4s, 1913-19 __ __ 4:%% basis New Haven (Conn.) Serv., 4s, 1913-25 __ __ 414% basis New Haven (Conn.) 31/2S, 1913-24 __ __ 4l^% basis New Haven Town (Conn.) 4s, 1939 __ __ 41/^% basis New Haven (Conn.) 31/3S, 1913-29 __ __ 414% basis New Haven (Conn.) 31/2S, 1922 __ __ *4.20 basis New Haven (Conn.) 31/3S, 1939 __ __ *90 New Haven (Conn.) 4s, 1929-30 __ __ 4.10% basis New London (Conn.) Sch. 4s, 1927 __ __ 98 New London (Conn.) Wtr., 31/2S, 1926 __ __ 92 New London (Conn.) 4y8S, 1941 __ __ __ *10iy8 Norfolk (Conn.) 4s, 1935 __ __ 98 Norfolk Town (Conn.) 31/2S, 1918 __ __ 95 Norfolk (Conn.) Wtr., 31/2S, 1929 __ __ 92 Norwich (Conn.) 4s, 1930 __ __ 98 Norwich Town (Conn.) 31/2S, 1925 __ __ 92 Orange (Conn.) Fund, 4s, 1925 __ __ 98 South Norwalk Conn.) 4i/4s, 1942 __ __ 4.30-20% basis South Norwalk (Conn.) 4s, 1935 __ __ *100 Stamford (Conn.) Park, 4s, 1942 __ __ __ 99 Waterbury (Conn.) 'Sch., 414s, 1921 __ __ 4.15% basis Waterbury (Conn.) Wtr., 414 s, 1971 __ __ 4.15%, basis Waterbury (Conn.) Wtr., 4s, 1920-49 __ __ 4.15% basis Waterbury (Conn.) Park, 4s, 1913-58 __ __ 4.15% basis Waterbury (Conn.) Sch., 31/2S, 1914-32 __ __ 4.15% basis Wallingford (Conn.) 41/3S, 1943-53 __ __ *4.15%, basis Willimantic (Conn.) 4s, 1934 __ __ 98 DELAWARE Delaware, 4s, 1933 __ __ ggi/g 100 Delaware Hos., 31/2S, 1915 __ __ 41/3% basis Delaware, 3s, 1937 __ __ 41/3% basis Newcastle Co. (Del.) 41/2S, 1936-34 __ __ 4.30% basis Newcastle Co. (Del.) Ref., 4s, 1913-34 __ __ 4.30% basis •Quotation nearest March 1, 1913. No quotation on that date. 1167 DELAWARE (Continued). High Low Bid Asked Newcastle Co. (Del.) 31/28, 1914-20 __ __ 4.30% basis Sussex Co. (Del.) 4s, 1913-22 __ — 41/8% basis Wilmington (Del.) 41/28, 1932 >_ — 4.20-10% basis Wilmington (Del.) St. & Sr., 41/2S, 1934 __ __ 4.20-10% basis Wilmington (Del.) 4s, 1925 __ — 4.20-10% basis FLORIDA Duval Co. (Fla.) 51/38, 1932 — __ 991/2 100 Duval Co. (Fla.) Road, 5s, 1939 — __ 10614 108 Apalachiola (Fla.) 6s, 15 yrs >_ „ •102.56 __ Bradentown (Fla.) 5s, 1933-43 __ — *5% basis Dade Co. (Fla.) 5s, 1923-33 __ __ *43/4% basis Ft. Lauderdale (Fla.) Wt., Sw. & St., 6s, 1932 — — __ *105.95 Franklin Co. (Fla.) Rd. 41/28, 1923-33 __ __ *4%%o basis Gulfport (Fla.) 6s, 1923 __ __ — 'lOO High Springs (Fla.) St., 6s, 1922-32 __ __ *5i/4% basis Jacksonville (Fla.) 5s, 1924 __ „ 1043/3 1051/4 Jacksonville (Fla.) Imp., 5s, 1936 _- — lOTVs 108% Jacksonville (Fla). 41/2S, 1936 — — IOOI/2 101 1/2 Jacksonville (Fla.) 41/2S, 1937 — — — 103l^ Key West (Fla.) 5s, 1935-55 __ __ •4.75%o basis Lakeland (Fla.) Sewer & St. 5s, 1942-56 __ __ __ *101 Pensacola (Fla.) Ref. 41/3S, 1941 „ __ __ IOI1/2 Tampa (Fla.) 6s, 1921 — — 4.60% basis Tampa (Fla.) 5s, 1955 __ __ 4.60 %basis St. Lucie Co. (Fla.) Rd., 5s, 1925-40 — __ *4.90%j basis St. Petersburg (Fla.) 6s, 1942 __ __ — *112 Titusville (Fla.) 5s, 28 yrs __ — *95 West Tampa (Fla.) 5s, 1941 ._ „ — *103i4 GEORGIA Georgia Ref., 41/28, 1914-16 __ __ 4.50-40%, basis Georgia 41/2S, Act of '84-'15 „ __ 99% 1001/2 Georgia 41/2S, 1922 — — 4.10-4% basis Georgia 4s, 1926 __ — 4-3%% basis Georgia 31/2S, 1917-35 __ — 4-3.65%, basis Georgia 31/38, 1929 — __ — *97 Georgia 31/38, 1920-30 __ __ „ *98i/2 Albany (Ga.) 5s, 1941 __ ._ — '108 Americus (Ga.) 41/38, 1941 _- __ — *100 Athens (Ga.) 58, 1922 — __ 4%-i/2% basis Atlanta (Ga.) Cap., 6s, 1914 __ __ 4.40-.30% basis Atlanta (Ga.) Red., 5s, 1915 __ __ 4.40-.30% basis Atlanta (Ga.) Red., 41/2S, 1916 — — 4.50-.30% basis Atlanta (Ga.) 41/38, 1932 — __ 4.50-.40% basjs Atlanta(Ga.) 41/38, 1940 — __ 4.50-.25%j basis Atlanta (Ga.) Sewer, 41/2S, 1916-40 — __ 4.35-.20% basis Atlanta (Ga.) Wtr., 4s, 1923 — -_ 4.40-.25%j basis Atlanta (Ga.) 31/38, 1931-33 „_ — 41/2% basis Augusta (Ga.) 6s, 1915 __ — 41/3% basis Augusta (Ga.) 5s, 1921 __ __ 4i/o% basis Augusta (Ga.) Flood Prot., 41/3S, 1942 — — 101 102 Augusta (Ga.) Red 41/38, 1924 __ __ 100 101 Augusta (Ga.) Ref., 48, 1934 — — 93 •Quotation nearest March 1, 1913. No Quotation on that date. 1158 GEORGIA (Continuea). High Low Bid Asked Augusta (Ga.) Si/gS, 1930 ■ — >_ 41/2% basis Augusta (Ga.) 41/2S, 1925 __ __ *4.40% basis Baxley (Ga.) 5s, 1934 — __ __ *96 Bogart (Ga.) Sch., 5s, 1924-43 __ __ __ *100 Buford (Ga. 5s, 1927-28 — -_ __ *97 Brunswick (Ga.) 5s, 1921 „ __ 100 103 Camilla (Ga.) Sewer, 51/2S, 1941 __ ._ — 'lOTy^ Chatham Co. (Ga.) 5s, 1913-19 _. __ 4.20% basis Claxton (Ga.) 53, 1931 — — — *96 Clarke Co. (Ga.) 5s, 1923-41 __ __ 41/3% basis Columbus (Ga.) 5s, 1913-22 __ __ 41/3% basis Columbus (Ga.) Ref., 4s, 1939 __ __ 4.50-.40% basis Columbus (Ga.) 31/38, 1931 __ __ __ *883^ Brunswick (Ga.) 5s, 1921 — __ 100 103 Doerum (Ga.) SVgS, 1942 __ __ __ *105 Fitzgerald (Ga.) 5s, 1942 — __ — *104 Gwinnett Co. (Ga.) Sch., 6s, 1943 __ __ __ *109.66 Macon (Ga.) 5s, 1923 __ __ 4.45-.30% basis Macon (Ga.) 41/38, 1926 — __ 4.45-.30% basis Macon (Ga.) W. W., 41/38, 1916-36 __ __ 4.45-.30% basis Macon (Ga.) Pav. 1/2 St., 4s, 1920-39 — __ 4.45-.30% basis Macon (Ga.) 4 1/3 s, 1939 __ __ __ *103 Manchester (Ga.) 5s, 1936-40 __ __ __ *99 McRae (Ga.) 5s, 1936 __ __ __ *96% Meigs (Ga.) Wtr. & Lt., 5s, 1934-37 __ __ __ *100 Ocilla (Ga.) Sewer, 6s, 1931-43 __ __ *4.85% basis Reidsville (Ga.) 5s, 1916 __ __ __ *98i/2 Rockmart (Ga.) 5s, 1920-31 __ __ __ *99 Rome (Ga.) 41/38, 1926 __ __ 97 98 Savannah (Ga.) 5s, 1913 __ __ 100 101 Savannah (Ga.) Ref., 41/28, 1959 __ __ 108 110 Statesboro (Ga.) Sewer, 5s, 30 yrs. __ __ *100.138 __ Washington (Ga.) 5s, 391/3 yrs __ __ *100 Waycross (Ga.) 5s, 1938 __ __ __ *103 Waycross (Ga.) 5s, 1918-42 __ __ *4.70% basis Wilcox C. (Ga.) 5s, 1933 1. __ ._ __ *97i/2 IDAHO Idaho, 5s, 1915 __ __ 100 Idaho, 41/2S, 1931 __ __ 4.30-.20% basis Bannock Co. (Id.) 6s, 1914-16 __ __ 4%% basis Blaine Co. (Id) 5s, 1922-31 __ __ 4.70% basis Shoshone Co. (Id.) 5s, 1915-24 __ __ 43/4% basis Boise City (Id.) 5s, 1922 __ __ 100 Boise City (Id.) S. D., 5s, 1925 — — 4%%, basis Boise City (Id.) 7s, 1 to 10 yrs __ __ 6.00-5.50% basis Nezperce (Id.) 51/38, 1933 __ __ __ *102.90 Idaho Co. (Id.) Sch., 51/2S, 1923-33 __ __ __ *104.70 Orofino (Id.) 68, 1922 __ __ — *104.23 Rupert (Id.) Sch., 51/2S, 20 yrs __ _. __ *103 ILLINOIS Altamont (111.) Wtr. & Sewer, 5s, 1921-32— „ — *4.60% basis Aurora (111.) 41/3S, 1917-32 __ __ *4l^% basis Bridgeport (111.) 5s, 1914-24 __ __ *4i/3% basis ♦Quotation nearest March I, 1913. No quotation on that date. 1159 ILLINOIS (Continued). Brookfield (111.) Water, 5s, 1920-21 Bumham (111.) 5s, 1921-31 Carbondale (111.) Rd., 5s, 1918 Cass Co. (111.) Sch., 5s, due serially Chicago Hghts. (111.) Water, 6s, 1914 Chicago (111.) 4s, 1915-22 Chicago (111.) 4s, 1913-28 Chicago (111.) Park, 4s, 1919-29 Chicago (111.) 4s, 1929 Chicago (111.) River, 4s, 1915 Chicago (111.) Imp., 4s, 1914-24 Chicago (111.) Wrlds Fair, 4s, 1921 Chicago (111.) 4s, 1914-25 Chicago (111.) Judg., 4s, 1914-24 Chicago (111.) Gen. Corp., 4s, 1914-25 Chicago (111.) 43, 1914-31 Chicago (111.) So. Pk., 4s, 1913-24 Chicago (111.) Line Pk., 43, 1923 Chicago (111.) W. Chic. Pk., 1913-31 Chicago (111.) Sou. Dis., 53, 1913-14 Chicago (111.) 'Sou. Dis., 41/2S, 1914-15 Chicago (111.) Sou. Dis., 4s, 1913-23 Chicago (111.) Sou. Dis., 4s, 1913-31 Chicago (111.) 4s, due Serially 1 to 20 yrs Chicago (111.) 4s, 1918 Chicago (111.) Sy^a, 1918-19 Chicago (111.) 4s, 1920 China (111.) Rd., 5s, 5% yrs Colfax (111.) Water, SVgS, 1918-31 Cook Co. (111.) 4s, 1913-23 Cook Co. (111.) Ct. H., 4s, 1913-25 Cook Co. (111.) 31/33, 1914-23 Cook Co. (111.) Sch., 41/28 Cook Co. (111.) 4s, Serially Cook Co. (111.) 4s, 1928 Decatur (111.) 4s, 1923-24 Edgar Co. (111.) Rd., 5s, 1915-21 Evanston (111.) 41/33, 1915-21 Ford Co. (111.) Sch., 5s, 1919-27 Hamilton (111.) Water, 5s, 1914-23 Hamilton (111.) Water, 53, 1922-31 Hamilton (111.) 53, Ser. 1924-31 Hamilton & Saline Cos. (111.) 5s, 1915-17 Hancock (111.) Co. Sch., 5s, Serially Kenilworth (111.) Sch., 5s, 1929 Lake Bluff (111.) 5s, Ser. 1914-32 Lyons (111.) 5s, 1912-18 Marion (111.) Sch., 4s, 1915-29 Moline (111.) 41/33, 1917-32 Monticello (111.) 5s, 1918-22 Normal (111.) St., 53, 1917 Pekin (111.) 5s, 1914-22 Peoria (111.) 43, 1917 Quincy (111.) Ref., 43, 1913-17 Rock Island (111.) Ref., 41/2S, 1913-17 'Quotation nearest March 1, 1913. No quotation on that date. 1160 High Low Bid Asked __ *100 *4.40% basis *43/4% basis *4i/2% basis _- *102% *4.15% basis *4.05% basis *4i/8% basis - *99i/2 995/8 99% 99y8 99% 99% 997/8 99% 99% 99% 99% 99% 99% 991/2 9934 99 991/2 99 991/2 99 991/2 1001/4 _- 4.15% basis 991A 99% 991/4 991/2 __ *96.074 __ *98.60 *4i/8% basis ♦9914 — *100.67 _- __ *104l^ 991/2 100 991/2 100 991/2 100 *4.40% basis 4.04% basis __ *100 - *97% *4.60% basis *4.30% basis ♦41/3% basis *5% basis ♦41/2% basis *4i/2% basis *100 *4ya% basis *4y2% •4.60% *5i/2% *4.20% 41/4% *4i/2% •4.40% basis basis basis basis basis 4.13% 41/4% basis ♦100 *99 basis basis ILLINOIS (Continued). St. Clair Co. (111.) Sch., 5s, 1918-23 St. Clair Co. (111.) Sch., 5s, 1933-27 Savanna (111.) Water, 5s, 1923-29 Shelby Co. (111.) Sch., 5s Springfield (111.) Ref., 31/38, 1920 Springfield (111.) SVgS, 1921 Springfield (111.) "Sch., 41/4S, 1915-32 INDIANA Indiana Fund, 31/28, 1915 (M. & N.) Indiana Fund, 31/2S, 1915 (A. & 0.) Blackford Co. (Ind.) 41/2S, 1 to 10 yrs Boone Co. (Ind.) Ct. H., 4s, 1913-20 Crawfordsville (Ind.) 4s, 1913-20 Evansville (Ind.) Ref., 4s, 1932 Evansville (Ind.) Ref., 4s, 1942 Evansville (Ind.) S. Cy., 31/2S, 1913-17 Floyd Co. (Ind.) 4s, 1914-30 Ft. Wawne (Ind.) 41/3S, 1913 Ft. Wayne (Ind.) 31/38, 1918-20 Ft. Wayne (Ind.) S. D. 4s, 1914-23 Franklin Co. (Ind.) 4s, 1913-20 Gary (Ind.) 6s, 1918-21 Hendricks Co. (Ind.) Ct. H., 4s, 1923-32 Huntington Co. (Ind.) 31/38, 1914-24 La Porto (Ind.) Sewer, 5s, 1913-21 Perry Co. (Ind.) 41/3S, 10 to 34 yrs Indianapolis (Ind.) 4s, 1924 Indianapolis (Ind.) Pk. Imp., 4s, 1927 Indianapolis (Ind.) Fire Dept., 4s, 1941 Indianapolis (Ind.) Hosp., 31/2S, 1936 Indianapolis (Ind.) C. H., 31/38, 1939 Indianapolis (Ind.) S. D., 48, 1913-26 Indianapolis (Ind.) Bldg., 4s, 1946 Jeffersonville (Ind.) Ref., 31/38, 1925 Knox Co. (Ind.) 4s, 1913-20 Kokoma (Ind.) 4s, 1916-31 - Lafayette (Ind.) 41/38, 1920 La Porte Co. (Ind. 5s, 1913-28 Logansport (Ind.) 31/38, 1926 Marion Co. (Ind.) Ref., 4s, 1921 Marion Co. (Ind.) Bridge, 31/3S, 1924 Marion Co. (Ind.) Ref., 31/38, 1925 New Albany (Ind.) 5s, 1915 Richmond (Ind.) 4s, 1927 Richmond (Ind.) Sch. Cy., 4s, 1919 St. Joseph Co. (Ind.) 31/3S, 1922-24 St. Joseph Co. (Ind.) 31/3S, 1914-26 South Bend (Ind.) 4s, 1925 South Bend (Ind.) 31/38, 1918 South Bend (Ind.) Sch. D., 48, 1917-27 Terre Haute (Ind.) 6s, 1913-18 Terre Haute (Ind.) 4s, 1915 - Terre Haute (Ind.) 48, 1927 Terre Haute (Tnd.) Sewer, 4s, 1930 Terre Haute (Ind.) Sch. Cy., 48, 1931 Vigo Co. (Ind.) 41/38, 1912-27 'Quotation nearest March 1, 1913. No Quotation on that date. 1161 High Low Bid Asked *4.40% basis *4i/3% basis *4.40% basis *4.40% basis 4.30% basis - *9378 *4.20% basis B%% basis B%% basis *100.92 __ 3%% basis 4% basis 99 99 4% basis 4% basis 41/3% basis 4% basis 4% basis 3%% basis __ *100 3%% basis 3%% basis -_ *100 *100.407 — 414% basis 4iA% basis 3.70% basis 3.80% basis 3%% basis 3%% basis 3.70% basis 4% basis 4% basis 4% basis 4% basis 4% basis 4l^% basis 4l^% basis 3%% basis 3%% basis 4% basis 4% basis 4% basis 3.85% basis 3.85% basis 4% basis 4% basis 4% basis 41/3% basis 4% basis 4% basis 4% basis 4% batis 3%% baiii High Low Bid Asked IOWA Atlantic (la.) SVgS, 1920 __ __ __ *94 Bedford (la.) 5s, 1921-33 __ __ *4i/2% basis Belle Plaine (la.) Sch., 41/28, 1921 __ __ __ *100 Belle Plaine (la.) Wtr. & Sewer 5s, 1918-28__ __ __ *4yo% basis Boone (la.) 41/38, 1917-31 __ __ 4.30% basis Boone (la.) 31/2S, 1919 ._ ._ >_ *94% Boone (la.) 41/2S, 1917-22 __ — __ *100 Boone (la.) 41/2S, 1928 __ __ __ *100 Burlington (la.) 4s, 1924 — __ 4.20% basis Cedar Rapids (la.) 41/2S, 1913-18 __ __ 4.10% basis Cedar Rapids (la.) 4s, 1913-19 __ __ 4.10% basis Cedar Rapids (la.) Sch. D., 4l^s, 1921 __ „ 4.50% basis Central City (la.) Wtr., 5s, 1932 — __ __ *104% Council Bluffs (la.) Wtr., 41/2S, 1916-30 __ __ 414% basis Council Bluffs (la.) Fire, 41/2S, 1920 __ __ 41/4% basis Council Bluffs (la.) Sch. D., 4s, 1920 __ __ 41/2% basis Council Bluffs (la.) 41/2S, 1915 __ __ __ *100 Davenport (la.) 4s, 1913-29 — „ 4% basis Davenport (la.) S. D., 4s, 1916 __ — 4% basis Davenport (la.) Sch., 41/2S, 1921 __ __ — *101s/8 Davenport (la.) 4s, 1922 — — *4 1/2% basis Davenport (la.) 4s, 1921-25 — — *4i4% basis Des Moines (la.) 41/2S, 1913-31 __ — 4.15-.10% basis Des Moines (la.) Fdg., 4s, 1916 — — 4.15-.10% basis Des Moines (la.) City HI., 4s, 1926 — __ 4%-i4% basis Dubuque (la.) 4s, 1917 — __ 4l^% basis Dubuque Co. (la.) 4l^s, 1921-31 — — 4%% basis Dubuque (la.) 1925 __ — *4.40% basis Iowa City (la.) Fund 5s __ __4.70-.50% basis Jackson Co. (la.) 5s, Ser. 1919-23 __ __ *4i/2% basis Jackson Co. (la.) 5s, 1913-30 __ __4.70- .50% basis Keokuk Co. (la.) 4s, 1919 __ __ *4i/2% basis Ottumwa (la.) 41/2S, 1917 — — 4l^% basis Ottumwa (la.) Sch. 41/2S, 1922 — __ — *101.55 Page Co. (la.) 6s, 1918-22 __ „ *5i/8% basis Polk Co. (la.) 41/2S, 1922-32 __ __ 414% basis Polk Co. (la.) Ct. Hse. 4s, 1924 __ __ 4.10% basis Polk Co. (la.) Ct. Hse. 31/28, 1917 — — 4.10% basis Polk Co. (la.) Ct. Hse. 41/2 s, 1920-24 __ __ *4.30% basis Seymour (la.) 5s, 1932 __ __ — *106.55 Waterloo (la.) Wtr. 41/2S, 1930 __ „ 414% basis Webster City (la.) Lt. 41/08, 1931-31 __ __ __ *100 Winnebago Co. (la.) 6s, 1914-24 __ — *5i/8% basis KANSAS Atchison (Kans.) 4s, 1915 — — — •9878 Atchison Co. (Kan.) Ref. 5s, 1916 — __ 104 IO41/2 Atchison Co. (Kan.) Ref. 4s, 1914 __ __ 90 94 Belle Plaine (Kans.) 5s, 1933-43 __ — *4.80% basis Caney (Kans.) 5s, 1928-29 , __ — — *102% Emporia (Kan.) 414s, 1929 __ — 100 Emporia (Kan.) S. D. 41/2S, 1922 — — 41/2% basis Ft. Scott (Kan.) 41/2^, 1935 „ __ 99 100 Ft. Scott (Kan.) V/^^, 1932-42 — — *^Vz% basis *Quotation nearest March 1, 1913. No quotation on that date. 1162 KANSAS (Continued). High Independence (Kans.) Water 4%s, 1936-40 Independence (Kans.) Water 4%s, 1942^ Hutchison (Kan.) 5s, 1913-15 Kansas City (Kan.) Ref. 6s, 1915 Kansas City (Kan.) 5s, 1917 Kansas City (Kan.) Sch. 41/28, 1939 Kansas City (Kan.) Wtr. Pit. Pur. 41/28 Kansas City (Kan.) Ref. 41/3S, 1939 Kansas City (Kan.) Ser. 5s, 1915-23 Kansas City (Kan.) 5s, 1918-33 Kansas City (Kan.) 5s, 1914-33 Kansas City (Kans.) 41/38, 1933-33 Kingman (Kans.) Elec. Lt. 5s, 1923-43 Mulberry (Kans.) Wtr. & Elec. Lt. 5s, 1923-43 Norton (Kans.) 5s, 1917-33 Norton (Kans.) 41/2S, 1933 Rosedale (Kans.) Wtr. 5s, 1932 Leavenworth (Kan.) 5s, 1915 Leavemvorth (Kan.) Fund 4s, 1914 Leavenworth (Kan.) Bd. Ed. 41/2S, 1921 Leavenworth Co. (Kan.) Ref. 5s, 1915 Sedgwick Co. (Kan.) Fund 5s, 1925 Shawnee Co. (Kan.) 4s, 1924 Topeka (Kan.) Wtr. 5s, 1926 Topeka (Kan.) El. Lt. 41/38, 1929 Topeka (Kan.) Wtr. 4s, 1924 Topeka (Kan.) Ref. 3%s, 1919 Topeka (Kan.) Sch. Dis. 48, 1925 Wichita (Kan.) 6s, 1915 Wichita (Kan.) 41/38, 1923 Wichita (Kan.) Sch. Dis. 41/3S, 1923 Wyandotte Co. (Kan.) Edge. 41/3S, 1932-41 KENTUCKY Corydon (Ky.) Elec. Lt. 6s, 1915-32 Fulton (Ky.) 68, Ser. 1913-33 Horse Cave (Ky.) Sch. 5s Lexington (Ky.) 6s, 1-10 yrs Lexington (Ky.) 68, 1917-33 Louisville (Ky.) Hosp. 41/3S, 1951 Louisville (Ky.) Imp. 4s, 1933 Louisville (Ky.) Imp. 4s, 1928 Louisville (Ky.) Park 4s, 1930 Louisville (Ky.) Ref. 48, 1937 Louisville (Ky.) Sewer 4s, 1947 Louisville (Ky.) Ref. 31/08, 1940 Louisville (Ky.) Ref. 31/38, 1943 Louisville (Ky.) Sr. & Pk. 3s, 1941 Nicholasville (Ky.) Sch. 58, 5-20 yrs McCracken Co. (Ky.) Rf. 5s, 1933, op. 1913___ McCracken Co. (Ky.) Rf. 58, 19133, op. 1923— _ Shelby Co. (Ky.) 5s LOUISIANA Louisiana 4s, 1914 Louisiana Pt. Com. 5s, 1924-59 Louisiana Port. Comm. 5s, 1928 •Quotation nearest March 1, 1913. No quotation on that date. 1163 Low Bid Asked — *4.60% basis __ *4.60% basis 100 — 4.30-.20% basis __4.30-.20% basis __4.30-.20% basis -4.45-4.35% basis -4.45-4.35% basis _- *4.35% basis __ *4.40% basis __ *4.40% basis 4.35% basis __ *103.63 *5% basis __ *100 __ *100 __ *104.78 98 93 95 __ 100 100 103 414% basis 97 100 __4.35-.25% basis __4.35-.25% basis __4.35-.25% basis __4.35-.35% basis 100 100 100 100 4.40% basis __ *5i/8% basis *5% basis *100 *100 __ *5.40% basis 108 100 101 1001/4 1011/3 10014 1011/3 1001/4 1011/3 1001/3 1011/3 90 911/3 90 91 80 __ *101.356 41/3% basis 41/3% basis *101.61 -_ 983/4 .- 4.40% basis __ *106 LOUISIANA (Continued). High Low Bid Asked Louisiana Port Comm. 5s, 1943-58 •4.40% basis Acadia (La.) 5s, Serially __ _- *100 Acadia (La.) 5s, 1920-40 „ __ __ *100 Atchafalaya Dist. (La.) Ref. & Imp. 5s, 1949— ♦llO Bossier Dist. (La.) Lev. 6s, 1923 — __ 991/2 __ Caddo Dist. (La.) (40-50) 5s, 1951 __ __ __ 971/2 Fifth District (La.) 5s, 1950 __ — 100 110 Fifth District (La.) 5s, 1952 MOS Fifth District (La.) 5s, 1954 *108 Fifth District (La.) 58, 1962 „ __ 110 Lake Borgne (La.) Dis. Lev. 5s, 1952 >_ „ HOi^ — Kentwood (La.) Wtr. & Sewer 5s, 1926-31 __ __ — *100 Madison Co. (La.) 5s, 1921-28 __ __ __ '100 Morehouse Co. (^La.) 5s, 1921-27 — ._ __ *100 Maryland SVgS, 1923-28 ._ ._ — *93y8 Maryland 4s, 1927-28 __ „ __ *99 Lewiston (Me.) 4s, 1913 __ __ *5% basis New Orl. (La.) Fltg. Debt 4s, 1948 __ ._ 85 95 New Orl. (La.) Constitutional 4s, 1942 __ __ 96 961/2 New Orl. (La.) 7s, 1922 *120i4 __ New Orl. (La.) Premium 5s 254 New Orl. (La.) Premium 5s, (dr'n. nos.) __ — 320 New Orl. (La.) Pub. Impvt. old 4s, 1950 __ __ 931/2 94% New Orl. (La.) Pub. Impvt. new 4s, 1942 >- __ 92 New Orl. (La.) Sch. Tchrs. Sal. 4s, 1927 — — 85 95 New Orleans (La.) 5s, 1916-25 — __ '4.90% basis New Orleans (La.) 5s, 1922-25 __ __ *4%% basis New Orleans (La.) 5s, 1915-27 _> ._ — •lOl Plaquemine Parish East Bank (La.) 5s, 1952 *102i/2 — Pontchartrain District (La.) D. 6s, 1944 *121 Red River (La.) A & B B Dis., 5s, 1950 ._ __ 102 Red River (La.) A & B B Dis., 5s, 1953 __ ._ IO21/2 106i/a St. Mary (La.) Sch., 5s, 1919-33 _> __ •4.90% basis Sabine (La.) Sch., 5s, 1913-22 __ __ ._ '100 Vermillion Co. (La.) 5s, 1920-27 — __. __ '100 MAINE Maine, 5s, 1919 __ __ 105 106 Maine, 5s, 1917 __ __ 99 Maine, 3s, 1913-29 __ __ 91 92 Aroostook Co. (Me.) 41/2S, 1915 __ __ 100 Aroostook Co. (Me.) C. H. 4s, 1925 98 Auburn (Me.) 31/2S, 1925 __ __ 90 Augusta (Me.) Ref., 4s, 1913-19 __ __ 98 101 Bangor (Me.) 4s, 1914 __ __ 99 Bangor (Me.) Ref., Wtr., 4s, 1935 98 Bath (Me.) Ref., 4s, 1941 __ __ 100 101 Belfast (Me.) 4s, 1918 __ __ 98 Cumberland Co. (Me.) 3y2S, 1921 __ __ __ 96 Gardiner (Me.) Wtr., Dis., 4s, 1934 __ __ 97 Kennebec (Me.) Wtr. Dis., 31/2S, 1925 __ __ 90 Lewiston (Me.) 5s, 1917 __ __ 102 103 Lewiston (Me.) 4s, 1927 __ __ 98 Portland (Me.) 4s, 1929 __ __ 971/, 98% Portland (Me.) Cy. HI., 4s, 1926-45 _- .. 3.80-75% basis ♦Quotation nearest March 1, 1913. No quotation on that date. 1164 MAINE (Continued). Portland (Me.) Ref., Si/gS, 1922 Portland (Me.) Bridge Dis., Si/gS, 1939. Portland (Me.) Wtr. Dis., 4s, 1928 Rockland (Me.) SVaS, 1917 Washington Co. (Me.) 4s, 1928 Waterville (Me.) 4s, 1927 Waterville (Me.) Si/gS, 1935 Westbrooke (Me.) 4s, 1915 MARYLAND Maryland 4s, 1927 Maryland Sy^s, 1919 Maryland State Rds., Sy^s, 1924 Maryland State Rds., SVaS, 1926 Maryland State Rds., Si/gS, 1927 Maryland 3s, 1914 Annapolis (Md.) 41/28, 1942 Attleborough (Md.) 4s, 1924 Attleborough (Md.) 31/2*, 1935 Arlington (Md.) Wtr., 4s, 1922 - Baltimore (Md.) 5s, 1916 Baltimore (Md.) Parks, 4s, 1955 Baltimore (Md.) Annex, 4s, 1954 Baltimore (Md.) 4s, 1920 Baltimore (Md.) Wtr., 4s, 1926 Baltimore (Md.) 4s, 1961 Baltimore (Md.) sy^s, 1930 Baltimore (Md.) Corp. stock 4s, 1961 Baltimore (Md.) Impvt., 31/285 1940 Baltimore (Md.) 31/2S, 1945 Baltimore (Md.) Ref., 31/2S, 1952 Baltimore (Md.) 3l^s, 1927 Beverly (Md.) Water, 4s, 1917 Beverly (Md.) Sewer, 4s, 1936 Cumberland (Md.) Wtr., 41/2S, 1941 Frederick (Md.) 48, 1918 Talbot Co. (Md.) 5s, 1-15 yrs Worcester Co. (Md.) 5s, 1914 MASSACHUSETTS Massachusetts 31/2S, 1918 Massachusetts 3l^s, 1923 Massachusetts 31/2S, 1935 Massachusetts Wtr., 31/2S, 1942 Massachusetts Wtr., 31/2S, 1944 Massachusetts 3s, 1915 Massachusetts 3s, Apr. 1929 Massachusetts 3s, May 1929 Massachusetts Met Swge., 3s, 1936 Massachusetts 3s, 1939 Massachusetts Wtr., 3s, 1941 Massachusetts 4s, 1916 Massachusetts 4s, 1916-17 Massachusetts 4s, 1916-18 Massachusetts 4s, 1920 "Quotation nearest March 1, 1913. No quotation on that date. 1165 High Low Bid Asked 94 951/3 4% basis __ 102l^ 95 98 98 90 98 99 93 93 93 93 98 90 991/2 933/8 93% 93% 93% 99 *102.06 102 961/2 97 961/2 97 98 100 98 100 961/4 _- 92 92 91 90 83 99 4.10% basis 100 1011/2 96 98 *102.27 — __ *100.58 4% basis 4% basis 91 92 893/4 __ 4% basis 4% basis 4% basis 4% basis 4% basis 4% basis 8II/2 821/2 __ *100.67 *3 3/4% basis *3%% basis __ *101.51 MASSACHUSETTS (Continued). Massachusetts SVgS, 1920 Massachusetts SVgS, 1922 Massachusetts 48, 1923 Massachusetts sy^a, 1922-25 Massachusetts 4s, 1916-26 Massachusetts 43, 1918-26 Massachusetts 4s, 1916-27 Massachusetts 4s, 1928 Massachusetts 4s, 1916-30 Massachusetts 3s, 1930 Massachusetts 31/28) 1931 Massachusetts 4s, 1933 •Massachusetts 3i/^s, 1933 Massachusetts 31/38, 1937 Massachusetts 3s, 1938 Massachusetts 31/28, 1938-39 Massachusetts 31/2S, 1931-40 Massachusetts 31/2S, 1940 Massachusetts 31/28, 1935-45 Massachusetts 4s, 1945 Massachusetts 31/2S, 1947 Massachusetts 31/2S, 1918-48 Massachusetts 31/2S, 1948 Massachusetts 31/2S, 1949 Massachusetts 4s, 1949-50 Massachusetts 48, 1913-52 Amesbury (Mass.) 4s, 1918 Arlington (Mass.) 4s, 1916 Attleborough (Mass.) 31/38, 1920 Attleborough (Mass.) 31/2S, 1935 Belmont (Mass.) 4s, 1943 Beverly (Mass.) 4s, 1921-23 Boston (Mass.) 3s, 1921 Boston (Mass.) 31/38, 1923 Boston (Mass.) 31/38, 1924 Boston (Mass.) 31/28, 1932 Boston (Mass.) 31/38, 1934 Boston (Mass.) 31/3S, 1935 Boston (Mass.) 31/38, 1943 Boston (Mass.) 31/3S, 1944 Boston (Mass.) 31/3S, 1945 Boston (Mass.) 4s, 1936 Boston (Mass.) 4s, 1913-37 Boston (Mass.) Wtr. 4s, 1919 Boston (Mass.) Park 4s, 1920 Boston (Mass.) Tun. & Sub. 4s, 1948 Boston (Mass.) Sub. 4s, 1957 Boston (Mass.) Wtr. 31/38, 1917 Boston (Mass.) Swge. 31/3S, 1919 Boston (Mass) 31/38, 1920 Boston (Mass.) 31/3S, 1919-36 Boston (Mass.) 31/38, 1936 Boston (Mass.) sy^s, 1922-44 Boston (Mass.) 4s, 1917-33 Boston (Mass.) 4s, 1923-33 Boston (Mass.) 48, 1933 •Quotation nearest March 1, 1913. No quotation on that date. 1166 High Low Bid *33/4% *33/4% *3.75% Asked *98.45 *983/s *103.49 basis basis basis basis __ *103.93 *3%% basis _- *87.32 basis basis — *963/4 *33/4% basis __ *88 *4% '3.75% *33/4% *3.90% *4.00% *4.05% *4.00% *33A% *3.75% basis basis basis basis basis __ *94i/4 *33A% basis - *953/8 *953/3 basis basis *99i/i *100.33 *96i/8 *90% *102% basis basis basis basis basis basis basis basis basis basis basis basis basis basis 102 basis basis basis *96% basis *90i/2 *88% basis basis *101.40 *33/4% 4.15-4% 4.15-4%, 4.15-4% 4.15-4% 4.15-4%, 4.15-4% 4.15-4% 4.15-4% 4.15-4% 4.15-4% 4.15-4%o 4.15-4% 4.15-4% 101 4.15-4%, 4.15-4%, 4.15-4%o 4.10% *3.85% ♦3.85%, MASSACHUSETTS (Continued). High Low Bid Asked Boston (Mass.) 4s, 1933-41 — — *3.90% basis Boston (Mass.) 4s, 1927-46 — — *4.10% basis Boston (Mass.) 4s, 1950 — — — *101.95 Boston (Mass.) 4s, 1917-58 — — *3.85% basis Brocton (Mass.) 4s, 1927 — — 98 Brocton (Mass.) Wtr., 31/28, 1932 — — 91 Brocton (Mass.) 31/38, 1916 — — — *98 Brocton (Mass.) 414s, 1920 — — — *101% Brocton (Mass.) 31/2S, 1934 __ — — *90% Brocton (Mass.) 4l^s, 1921-43 — — *4% basis Brookline (Mass.) 4s, 1913-23 — — 99 Brookline (Mass.) 31/2S, 1915 — — — *99 Cambridge (Mass.) Wtr., 4s, 1917 — — 99 Cambridge (Mass.) 31/2S, 1925 __ __4.12i/2-.05% basis Cambridge (Mass.) Bdge, 3s, 1941 __ — 81 Cambridge (Mass.) 31/2S, 1930 __ — — *95 Cambridge (Mass.) 4s, 1923-33 __ — *3%% basis Cambridge (Mass.) 31/2S, 1939 — — — *90y2 Cambridge (Mass.) 31/2S, 1942___ — — — *90i/8 Cambridge (Mass.) 31/2S, 1944 __ — — *90% Canton (Mass.) 4s, 1922-24 __ — *4.20% basis Chelsea (Mass.) Park, 4s, 1936 — — 98 Chelsea (Mass.) 4s, 1958 __ „ — *100 Chelsea (Mass.) Si/gS, 1959 __ __ — *89y3 Chicopee (Mass.) 4s, 1918-19 — — *4l^% basis Chicopee (Mass.) 4s, 1913-21 — — *3.70% basis Chicopee (Mass.) 4s, 1916-21 — — *3.85% basis Chicopee (Mass.) 4s, 1921-35 __ — *3.80% basis Concord (Mass.) 31/2S, 1929 — — — *96y8 Concord (Mass.) 4s, 1937-42 — — *3.90% basis Concord (Mass.) 4s, 1940-42 — — *3.90% basis Danvers (Mass.) Elec. Lt., 4s, 1915 __ __ „ *99% East Bridgewater (Mass.) Wtr, 41/2S, 1-30 yrs. __ __ *101i/2 — East Bridgewater (Mass.) 4i/4s, 1924-41 __ *4% basis Essex Co. (Mass.) 31/2S, 1916 __ — — *98 Everett (Mass.) Swr. 4s, 1929 __ __ 98 Everett (Mass.) 4s, 1921 — __ __ *99iA Everett (Mass.) 4s, 1924 __ __ __ *99 Fall River (Mass.) 4s, 1942 __ __ __ *102 Fall River (Mass.) Sch., 414s, 1913 __ __ 991/2 — Fall River (Mass.) Mun., 4s, 1922 __ __ __ 102y2 Fall River (Mass.) Wtr., 31/2S, 1920 __ __ 92 Fall River (Mass.) 31/38, 1924 __ __ __ *95% Fall River (Mass.) 4s, 1922-23 __ __ __ *100y8 Fall River (Mass.) 31/38, 1925 __ __ __ *94l^ Fall River (Mass.) 31/38, 1934 __ __ __ 931/3 Fall River (Mass.) 31/38, 1930 __ __ „ *92y^ Fall River (Mass.) 4s, 1938 __ __ __ *98 Fall River (Mass.) 31/38, 1939 __ __ __ *93i/2 Fitchburg (Mass.) Reg., 4s, 1922 __ __ 99 Fitchburg (Mass.) Wtr., 31/3S, 1926 __ __ 92 Franklin (Mass.) Wtr., 4s, 1922-25 __ __ *4.15% basis Gardner (Mass.) Wtr., 48, 1913-34 __ __ 97 Gardner (Mass.), Wtr., 4s, 1931-32 __ __ *4.15% basis Gloucester (Mass.) Wtr., 31/38, 1913-31 __ __ 4.15-.10% basis ♦Quotation nearest March 1, 1913. No quotation on that date. 1167 MASSACHUSETTS (Continued). High Low Gloucester (Mass.) SVgS, 1921 Haverhill (Mass.) 48, 1927 Haverhill (Mass.) 4s, 1917-22 Heverhill (Mass.) 4s, 1922 Holyoke (Mass.) 4s, 1927 Holyoke (Mass.) SVzS, 1913-32 Holyoke (Mass.) 3yaS, 1928 Holyoke (Mass.) BYzS, 1932 Hudson (Mass.) 4s, 1921 Indianola (Mass.) Sch. 5s, 5-20 yrs Ipswich (Mass.) 43, 1924 Lawrence (Mass.) 4s, 1924 Lawrence (Mass.) 4s, 1014-22 Lawrence (Mass.) 4s, 1919 Lawrence (Mass.) 4s, 1923 Leominster (Mass.) 43, 1926 Lowell (Mass.) Wtr., 4s, 1920 Lowell (Mass.) 4s, 1919-22 Lynn (Mass.) 4s, 1927 Lynn (Mass.) sy^s, 1932 : Lynn (Mass.) 4s, 1917 Lynn (Mass.) 43, 1919 Lynn (Mass.) 31/28, 1932 Lynn (Mass.) 4s, 1917-42 Maiden (Mass.) 4s, 1924 Maiden (Mass.) Wtr., SVgS, 1924 Maiden (Mass.) 4s, 1926 Maiden (Mass.) 3y2S, 1935 Maiden (Mass.) 4s, 1942 Mansfield (Mass.) 4s, 1918 Mansfield (Mass.) 4s, 1933 Marblehead (Mass.) 4s, 1919 Marlborough (Mass.) 4s, 1915 Marlborough (Mass.) 4s, 1926 Marlborough (Mass.) 4s, 1918 Medford (Mass.) 4s, 1917 Medford (Mass.) 4s, 1930 Melrose (Mass.) 4s, 1924 Methuen (Mass.) 43, 1928 Middleboro (Mass.) 4s, 1921 Middlesex Co. (Mass.) 4s, 1916-21 Milton (Mass.) 3sy2, 1913-32 Milton (Mass.) sygS, 1919 Natick (Mass.) 31/28, 1924-25 Natick (Mass.) 31/28, 1925 ■NTatick (Mass.) 31/28, 1026-28 Needham (Mass.) 31/33, 1931 New Bedford (Mass.) 4s, 1957 New Bedford (Mass.) 41/2S, 1917 New Bedford (Mass.) Wtr., 4s, 1926 New Bedford (Mass.) Swr. 4s, 1913-41 New Bedford (Mass. 31/2S, 1918 New Bedford (Mass.) 4s, 1916-22 New Bedford (Mass.) 31/28, 1922 New Bedford (Mass.) 4s, 1928 New Bedford (Mass.) 4s, 1935 ^Quotation nearest March 1, 1913. No quotation on that date. 1168 Bid Asked *955/3 98 99 *3.90% basis *iooy4 98 99 3.85% basis __ *938/8 *98i/8 *99i/2 100 __ *98 96 4.15% basis *100.53 *99 971/2 -- 98 __ •33/4%, basis 98 91 *993/4 *100 *913/4 *100 98 93 _ *983/4 •91% — ♦1031/3 *993/8 __ •981/4 •1001/2 99 98 •1001/2 99 98 98 98 •98% 99 92 __ •97 *4.10% basis •94 *4.20% basis ♦90% •97y4 102 98 3.85% basis •41/8% basis •100 •951/2 •100 •98% MASSACHUSETTS (Continued). High New Bedford (Mass.) 31/38, 1951 Newburyport (Mass.) Wtr., 31/2S, 1913-34 Newburyport (Mass.) 4s, 1914-23 Newton (Mass.) Wtr., 4s, 1935 Newton (Mass.) Wtr., 31/28, 1926 Newton (Mass.) 31/2S, 1922 Newton (Mass.) 31/2S, 1931 Newton (Mass.) 4s, 1936 Newton (Mass.) 4s, 1939 No. Andover (Mass.) 48, 1923 No. Attleboro (Mass.) 4s, 1913-18 No. Attleboro (Mass.) 4s, 1918 No. Attleboro (Mass.) 4s, 1922 Northampton (Mass.) 31/2S, 1913-26 Palmer (Mass.) 414s, 1913-19 Peabody (Mass.) 4s, 1917-21 Peabody (Mass.) 4s, 1925 Pittsfield (Mass.) Sch., 4s, 1913-17 Pittsfield (Mass.) 31/2S, 1915 Pittsfield (Mass.) 4s, 1923 Quincy (Mass.) 4s, 1913-22 Quiney (Mass.) 4s, 1918 Quincy (Mass.) 4s, 1915 Quincy (Mass.) 31/2S, 1924-26 Quincy (Mass.) 31/2S, 1926 Quincy (Mass.) 4s, 1926 Quincy (Mass.) 4s, 1928-37 Quincy (Mass.) 31/2S, 1931-38 Salem (Mass.) 4s, 1921 Salem (Mass.) 4s, 1926 Salem (Mass.) 31/oS, 1940 Sharon (Mass.) 4s, 1921 Shelburne Falls (Mass.) 41/38 Somerville (Mass.) 4s, 1913-19 Somerville (Mass.) 4s, 1927-38 So. Hadley (Mass.) 4s, 1917-28 Springfield (Mass.) Wtr., 4s, 1913__ Springfield (Mass.) Sch., 4s, 1917 Springfield (Mass.) 31/2S, 1913-18 Springfield (Mass.) Sch. 31/38, 1925 Springfield (Mass.) Swr., 3s, 1930J Springfield (Mass.) 31/38, 1929 Stockbridge (Mass.) 4s, 1923-32 Swampscott (Mass.) 31/38, 1925 Swampscott (Mass.) 314s, 1926 Swampscott (Mass.) 3l^s, 1928 Taunton (Mass.) 4s, 1927 .__ Taunton (Mass.) Swr., 31/38, 1930 Taunton (Mass.) 31/3S, 1932 Wakefield (Mass.) Wtr., 4s, 1913-33 Wakefield (Mass.) Sch., 4s, 1-10 yrs Wakefield (Mass.) 31/38, 1923-30 Wakefield (Mass.) 4s, 1930 Waltham (Mass.) Wtr., 4s, 1913 Waltham (Mass.) 31/38, 1920 Waltham (Mass.) 48, 1928-31 Watertown (Mass.) 4s, 1913-34 •Quotation nearest March 1, 1913. No quotation on that date, 1169 Low Bid Asked -_ *873/4 4.10% basis __ *4i^% basis 98 93 - "95% - *923/8 - *98 __ *99i/2 - *99 __ *3.85% basis __ '99% __ *100% 95 __ *3.80% basis __ *4i4% basis __ *97% 3.85% basis __ *983/4 __ *100% — 4.15-.10% basis - *99% __ *100i/4 __ 4.10% basis __ *938^ „ *98i/4 __ *3.80% basis __ *4.10% basis __ '101.69 __ *102.57 _. *90i/8 99 :: " *io4i/2 99 __ noii/a „ *100 993/4 „ 99 981/3 - 941/4 -- 86I/2 - - *95% __ *3%% basis __ *92% __ *94 __ *94i/a 98 92 _- *92iA 971/2 - *100.14 __ __ *4.10% basis __ *99 991/3 -_ 95 3.90% basis 971A - MASSACHUSETTS (Continued). High Low Bid Asked Westfield (Mass.) SVgS, 1927 — — — *93% Weymouth (Mass.) 4s, 1919 — __ -_ *99iA Whitman (Mass.) 1916 — __ — *99% Winchester (Mass.) Swr., 4s, 1918-24 __ __ 99 Winchester (Mass.) Sch., Zy^s, 1917-18 __ — *4.15% basis Worcester (Mass.) 4s, 1922 — — 99 Worcester (Mass.) SVgS, 1922 __ — 951/2 __ Worcester (Mass.) 4s, 1922 __ — — *101.19 Worcester (Mass.) 4s, 1917-23 __ „ *3.85% basis Worcester (Mass.) 4s, 1920-29 __ — *3.85% basis. Worcester (Mass.) 4s, 1917-33 __ — *3.85% basis Worthington (Mass.) 4s, 1936-40 __ __ — *100 Wrentham (Mass.) 4s, 1934-36 __ >_ *4.15% basis MICHIGAN Alger Co. (Mich.) Road, 5s, 1922 „ __ To net 4.40% Ann Arbor (Mich.) Sch. Dis., 4s, 1935 „ __ To net 4.10% Ann Arbor (Mich.) 4s, 1920 — — — *983/8 Battle Creek (Mich.) Wtr., 5, 1915-17 — — To net 41/2% Bay City (Mich.) 8s, 1913 — __ 41/2% basis Bay City (Mich.) 5s, 1920 __ __ 41/2% basis Bay City (Mich.) 4s. 1934 __ __ 41/2% basis Bay Co. (Mich.) 5s, 1919 __ — 41^% basis Bay Co. (Mich.) Ref., 4s, 1923 __ __ 4.30% basis Benton Harbor (Mich.) Pk., 4s, 1933 __ __ 41/2% basis Brown City (Mich.) 4s, 1928-34 __ __ •4.35% basis Carson City (Mich.) 4y2S, 1917-20 __ — *4.20% basis Crystal Falls (Mich.) Sch., 5s „ __ *4.30% basis Delta Co. (Mich.) Rd., 4y2S, 9^4 yrs __ __ *101.155 — Detroit (Mich.) Swr., 4s, 1922 __ — 4% basis Detroit (Mich.) Pub. Imp., 3.65s, 1918 __ __ 4% basis Detroit (Mich.) Park, 31/2S, 1930 __ __ 4% basis East Towas (Mich.) 1921 __ __ __ *97 Flint (Mich.) Sch., 41/28, 12l^ yrs __ __ *102.527 — Flint (Mich.) 41/2S, 1914-37 — _. *4.10% basis Gladstone (Mich.) 41/2S, 1919 __ __ 41/2% basis Grand Haven (Mich.) Sch., 4s, 1932 __ __ *4i4% basis Grand Rapids (Mich.) Flood Prot., 41/2S, 1933 — __ 4.20-.10% basis Grand Rapids (Mich.) Mkt., 4s, 1916 __ __ 4.20-10% basis Grand Rapids (Mich.) Wtr., 4s, 1929 __ __ 4.20-.10% basis Grand Rapids (Mich.) 4s, 1931 __ __ «_ "lOO Hamtramck (Mich.) 5s, 1938 __ __ __ •110.78 Hancock (Mich.) 5s, 1914-18 __ __ ♦414% basis Hancock (Mich.) 41/2S, 1919 __ __ __ *101i/2 Highland Park (Mich.) Sch., 41/2S __ __ •4.20% basis Holland (Mich.) Ref., 4s, 1914-23 __ __ 41/2% basis Holland (Mich.) 41/4 s, 1914-22 __ __ ^4.08% basis Jackson (Mich.) 4s, 1930 __ __ __ •99.40 Lake Odessa (Mich.) Wtr., 5s, 1922-27 __ __ *4.15% basis Lansing (Mich.) 5s, 1913-23 __ __ 41/2-4% basis Lansing (Mich.) Wtr., 4s, 1920 __ __ 41/2-4% basis Marquette (Mich.) 4s, 1916 . __ __ 41/2% basis Muskegon (Mich.) Sch., 41/2S, 1915-20 __ __ •4.10% basis Muskegon (Mich.) 41/2S, 1926 __ __ __ ^1041/8 Muskegon (Mich.) Wtr., 5s, 1913-25 __ __ 4.60% basis Muskegon (Mich.) Wtr. Wks., 41/2S, 1915-44- _ __ __ 4.60% basis •Quotation nearest March 1, 1913. No quotation on that date. 1170 MICHIGAN (Continued). High Low Bid Asked Muskegon (Mich.) 4s, 1934 __ __ 4.50% basis Muskegon (Mich.) Sch. Dis., 5s, 1943— — __ 4.50% basis Muskegon Co. (Mich.) 41/28, 1933 __ __ 4.50% basis Owosso (Mich.) Ref., 4s, 1930 __ __ 41/3% basis New Baltimore (Mich.) 4y2S, 1933 __ __ — *100 Oceana Co. (Mich.) 53, 1918-37 __ — *4.40% basis Oscoda (Mich.) 5s, 1914-38 __ __ *4.30% basis Petoskey (Mich.) 4l^s, 1930 >. __ __ *101 Pigeon (Mich.) 1917-37 „ __ __ *106 Pontiac (Mich.) Sch., 41/28, 14 yrs __ __ *103.571 — Port Huron (Mich.) Ref., 4s, 1919 __ __ 4.60% basis Port Huron (Mich.) 4s, 1933 __ __ 4.60% basis Port Huron (Mich.) Pk., 31/2S, 1930 __ __ 4.60% basis Port Huron (Mich.) 41/3S, 1914-38 __ __ *4.10% basis Riverton (Mich.) Rd., 5s, 1917-31 __ __ *4l^%, basis St. Joseph (Mich.) 41/2S, 1937 __ __ __ *101 St. Johns (Mich.) 5s, 1914 __ __ 4.30-.S0% basis Saginaw (Mich.) Wtr., 41/2 s, 1935 __ __4.30-.30% basis Saginaw (Mich.) "Swr., 4s, 1918 __ __ 4.30-.30% basis Saginaw (Mich.) Wtr., 31/2S, 1930 __ __ 4.30-.30%, basis Sault Ste. Marie (Mich.) Wtr., 6s, 1913 __ __ 4.60% basis Sault Ste. Marie (Mich.) Ref., 5s, 1917 __ __ 4.50% basis Sault Ste. Marine (Mich.) Bdge., 41/2S, 1930— __ __ 4.50% basis Sault Ste. Marie (Mich.) 4s, 1933 __ __ 4.50% basis South Haven (Mich.) 5s, 1918-33 __ __ *4i4% basis Travers City (Mich.) El. Lt. & Pr., 4l^s, 1933 __ __ *4.10%, basis Wayne Co. (Mich.) 31/2S, 1914 __ __ 4.10-.39% basis Wyandotte (Mich.) 41/2S, 1934 __ __ 4.40% basis MINNESOTA Otter Tail Co. (Minn.) Ditch, 5s, 1918-33 __ __ 4.45%, basis Beltrami Co. (Minn.) 41/2S, 1913-34 __ __ 4%% basis Clay Co. (Minn.) 41/2S, 1915-16 __ __ 41/2%, basis Crookston (Minn.) Ind. 5 D, 41/oS, 1937 __ __ __ 100 Cass Co. (Minn.) Sch., 5s, 1934_''_ __ __ __ *103.37 Duluth (Minn.) Wtr. & St., 5s, 1936 __ __ 4.35%, basis Duluth (Minn.) 41/2S, 1936 __ __ 4.35%, basis Duluth (Minn.) Wtr., 4s, 1938 __ __ 4.35% basis Duluth (Minn.) Wtr. & Lt., 4s, 1936 __ __ 4.35%, basis Duluth (Minn.) Ind. S. D. 5s, 1913 __ __ 100 Duluth (Minn.) Ind. S. D. 5s, 1933 __ __ 41/2% basis Duluth (Minn.) Ind. S. D. 41/2S, 1940 __ __ IOII/2 IO31/3 Duluth (Minn.) Ind. S. D. 4s, 1934 __ __ 41/2% basis Duluth (Minn.) Wtr. & Lt., 41/pS, 38 yrs __ __ *100 Duluth (Minn.) Sch., 41/2S, 1931 __ __ __ *101 Duluth (Minn.) Sch., 5s, 1933 __ __ __ *105 Duluth (Minn.) Wtr., 4s, 1938-36 __ __ *4.40% basis Duluth (Minn.) 41/2S, 1941 __ __ __ *10314 Grand Rapids (Minn.) Rd., 5s, 1937 __ __ __ *103.54 Greenbush (Minn.) 6s, 1933 __ __ __ *107.18 Hennepin Co. (Minn.) 41/2S, 1934 __ __ __ *103 Jackson Co. (Minn.) 5s, 1913-31 __ __ 4.55% basis Koochiching Co. (Minn.) 4s, 1935-31 __ __ *4i/2% basis Lac Qui Parle Co. (Minn.) 5s, 1930-30 __ __ 4.55% basis Marshall Co. (Minn.) 51/2S, 1918-33 __ __ *4%% basis Marshall Co. (Minn.) Ser., 51/3S, 1918-38 _. __ *4.60% basis •Quotation nearest March 1, 1913. No quotation on that date. 117X MINNESOTA (Continued). Marshall Co. (Minn.) Ditch 5s, 1913-29 Polk Co. (Minn.) Sch. Dis., 58, 1927 Ramsey Co. (Minn.) 5s, 1915 Ramsey Co. (Minn.) Ct. Hse., 41/28, 1916 Ramsey Co. (Minn.) Si/gS, 1921 Red Lake Co. (Minn.) SVjjS, 1920. High Low s (Minn.) Park, 41/2S, 1913 3 (Minn.) 41/28, 1920 s (Minn.) Sch., 4s, 1927 s (Minn.) Sch., 4s, 1935 s (Minn.) Imp., 4s, 1937 s (Minn.) Imp., 4s, 1942 8 (Minn.) Sch., 31/2S, 1929 8 (Minn.) Wtr. Wks., 31/2S, 1932. s (Minn.) Wtr. Wks., 41/2S, 1914_. s (Minn.) 4s, 1917 s (Minn.) 43, 1918 3 (Minn.) 4s, 1922 8 (Minn.) 4s, 1941 8 (Minn.) 43, 1942 Minneapol: Minneapol Minneapol Minneapol Minneapol Minneapol Minneapol Minneapol Minneapol Minneapol Minneapol Minneapol Minneapol Minneapoli Rosean Co. (Minn.) 6s, 1919-33 Rosean Co. (Minn.) 63, 1925-33 St. Paul (Minn.) Wtr., 5s, 1915 St. Paul (Minn.) 41/38, 1917 St. Paul (Minn.) Wtr., 41/38, 1918 St. Paul (Minn.) Ref., 48, 1939 St. Paul (Minn.) Sw'ge, 4s, 1939 St. Paul (Minn.) 43, 1940 St. Paul (Minn.) 31/2S, 1922 Osakis (Minn.) Sch., 41/2S, 1917 Skakopee (Minn.) Wtr., 5s, 31/2 yrs Virginia (Minn.) Wtr. & Lt., 5s, 15 yrs.. Bid Asked 4.65% basis __ 1021/3 4.15% basis 4.15% basis 4.15% basis 4.60% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis -_ *100 - *99% - '99 - •988/8 _- *973/4 *4.125% basis *5% basis *5% basis 4.15 %basi3 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis - *^W» •100 •lOli/a - MISSISSIPPI Mississippi 31/38, 1934 Adams Co. (Miss.) Rd., 5s, 1952 Bolivar Co. (Miss.) 6s, 1914-31 Chickasaw Co. (Miss.) Rd., 5s, 1925-27 Covington Co. (Miss.) Rd., 6s, 1927 Reene Co. (Miss.) 6s, 1923 Greenwood (Miss.) 58, 1926 Hancock Co. (Miss.) Rd., 6s, 1933 Itawamba Co. (Miss.) 6s, 1913-32 Jackson (Miss.) Wtr., 58, 1928 Jackson (Miss.) 5s, 1932 Jackson (Miss.) 5s, 1930 Lauderdale Co. (Miss.) 51/28 Lauderdale Co. (Miss.) 51/38, I714 yrs Le Flore Co. (Miss.) 6s, 1921-30 Lincoln Co. (Miss.) 51/38, 1923-37 Marks (Miss.) Wtr. & Sewer, 6s, 1931 Miss. Levee Dist., 58, 1944 Miss. Levee Dist., 41/33, 1934 Mize (Miss.) Sch., 68, Ser. 1913-26 Monroe Co. (Miss.) Rd., 5s, 1927-37 Noxubee Co. (Miss.) Rd. 51/38, 1928-37 ^Quotation nearest llarcb 1, 1913. No quotation on tliat date. 1173 _- *90 *4.65% basis •5.40% basis *5% basis __ *109.64 •4.70% basis •4.80% basis •5% basis •51/3% basis 4%% basis 103 105 •4.50% basis 5% basis •100.11 _- •53/4% basis ♦5% basis __ •104.70 104 105 100 101 •51/2% basis •5% basis •5%% basis MISSISSIPPI (Continued). Prentiss Co. (Miss.) 6s, 1913-33 Richton (Miss.) 6s, 1932 Sunflower Co. (Miss.) 6s, 1921-30 Tallahatchie Co. (Miss.) Rd., 6s, 1926-34 Tallahatchie Co. (Miss.) Rd., 6s, 1922-36 Tutwiler (Miss.) Wtr., 6s, 20 yrs Vicksburg (Miss.) St. Imp., 5s, 1913-32 Vicksburg (Miss.) Swr., 41/23, 1928 Yazoo (Miss.) Delta Lev. Dis., 6s, 1947 Yazoo (Miss.) Delta Lev. Dis., 41/33, 1949 Yazoo (Miss.) Delta Lev. Dis., 1952 Yazoo (Miss.) Delta Lev. Dis., 5s, 1924 Yalobusha Co. (Miss.) Rd., 5s, 1934-37 High Low Bid Asked *5 1/2% basis *5i4% basis 51/2% basis __ *5.30 %basis _- *5i/4% basis *100 — 4.80-.65% basis 4%% basis 103 106 102 104 92 94 __ *4.80% basis _- *100 MISSOURI Bates Co. (Mo.) 6s, 1922-30 — __ *5l^% basis Bertrand (Mo.) Sch., 5s, 1932 — — — *102l^ Crooked River (Mo.) 6s, 1914-23 — -_ *5l^% basis Duenweg (Mo.) Sch., 5s, 1922-32 — — — "102.80 Dunklin Co. (Mo.) 6s, 20 yrs — — $100,385 __ Dunklin Co. (Mo.) 6s, 1917-19 — — — *101 Excelsior Springs (Mo.) 'Sewer, 5s, 1932 — — — *104.86 Farmington (Mo.) Elec. Lt., 5s, 1928 __ — — *100i4 Ferguson (Mo.) 5s, (various maturities) __ __ *4%% basis Hannibal (Mo.) Sch., 4s, 1915 — __ — *99 Higginsville (Mo.) Wtr. & Lt., 5s, 1923-33 __ __ *4.70% basis Huntsvillc (Mo.) Wtr. & Lt., 5s, 1921-30 __ — — *101.88 Kansas City (Mo.) Westpt., 5s, 1916 __ __ 102 Kansas City (Mo.) Wtr., 41/2S, 1915 __ __ IOOI/2 lOiy, Kansas City (Mo.)Mkt. Hse., s4, 1924 __ __ 99 100 Kansas City (Mo.) Wtr., 43, 1924 __ __ 99 100 Kansas City (Mo.) Pk. & Blvd., 4s, 1924 __ __ 99 100 Kansas City (Mo.) 6s, Ser. 1 to 10 yrs __ — *100i/2 — Kansas City (Mo.) Sewer, 41/2S, 1930 __ __ __ *104i4 Kansas City (Mo.) Park Dist., 7s, 1913-21 __ __ 41/3% basis Kansas City (Mo.) Sch. Dist., 4s, 1914 __ __ 991/2 __ Kansas City (Mo.) Sch. Dist., 4s, 1927 — __ 99 Kansas City (Mo.) Sch. Dist., 4s, 1930 __ ._ 99 Kansas City (Mo.) Sch. Dist., 31/2S, 1923 __ __ 93 94 Kansas City (Mo.) Sch. Dist., 31/2S, 1925 __ ._ 92 94 Jefferson Co. (Mo.) Ref., 41/2S, 1914-19 __ __ 4%% basis Jefferson (Mo.) 41/2S, 1922-32 _- __ __ __ *102 • Lewis & Clark Co. (Mo.) C. H., 51/28, 1913-19-_ __ __ 4.70% basis Lincoln Co. (Mo.) 5s, 1932 __ __ 4%% basis Lincoln Co. (Mo.) Fund, 5s, 1931 __ __ 4%% basis Maryville (Mo.) Wtr., 4%s, 1917-32 __ __ __ "lOLS? Mexico (Mo.) Sch., 41/2S, Ser. 6-20 yrs __ __ *100 Mountain Grove (Mo.) Wtr., 53, 1922-32 __ __ __ *101.89 Missoula (Mo.) 41/2S, 1924 __ __ 4%% basis Missoula Co. (Mo.) Ref., 4s, 1921 __ __ 4.70% basis New Madrid Co. (Mo.) 6s, 1915-16 __ __ *5i4% basis Pemiscot Co. (Mo.) 6s, 1918-32 __ _. *5i4% basis Poplar Bluff (Mo.) Sch., 5s, 1923-33 __ __ *4.70% basis Pettis Co. (Mo.) 4s, 1918 __ __ 41/3% basis Richmond (Mo.) "Sewer, 5s, 1917-32 __ __ *4.80% basis St. Louis (Mo.) Ren'l, 3.65s, 1927 ._ __ 95% 9614 •QuoUtion nearest March 1, 1913. No quotation on that date. 1173 MISSOURI (Continued). High St. Louis (Mo.) Ren'l, 3.65s, 1915 St. Louis (Mo.) Ren'l, SVgS, 1918 St. Louis (Mo.) 31/28, 1925 St. Louis (Mo.) 3y4S, 1922 St. Louis (Mo.) 31/2S, 1919 St. Louis (Mo.) 31/2S, 1920 St. Louis (Mo.) Ren'l, 4s, 1913 St. Louis (Mo.) Ren'l, 4s, 1914 St. Louis (Mo.) Ren'l. 4s, 1918 lOOVs St. Louis (Mo.) Ins. Asylum, 4s, 1928 St. Louis (Mo.) Pub. Imp., 4s, 1928 St. Louis (Mo.) Pub. Bldg., 4s, 1929 St. Louis (Mo.) Wtr. Wks., 4s, 1931 Scotland Co. (Mo.) 41/2S, 1917 Scotland Co. (Mo.) 41/2S, 1917 Sedalia (Mo.) Rd., 5s, Ser. 1914-24 Sedalia (Mo.) Rd., 5s, Ser. 1914-27 Sheldon (Mo.) Sch., 5s, 1919-20 Silver Bow Co. ( Mo.) Fund, 53, 1917 Springfield (Mo.) 5s, 1932 Yellowstone Co. (Mo.) Ref., 5s, 1918 MONTANA Bozeman (Mont.) 5s, 1919 Beaverhead Co. (Mont.) Sch., 5s, 10-20 yrs.__ Butte (Mont.) 4%^, 1925 Butte (Mont.) Sch. Dis., 41/23, 1924 Cascade Co. (Mont.) 4s, 1921 Chinook (Mont.) 6s, 8 yrs Custer Co. (Mont.) 6s, 1925 Deer Lodge Co. (Mont.) 5s, 1919 Glasglow (Mont.) 51/2S, 1924-29 Glasglow (Mont.) Wtr., 51/2S, 1929 Great Falls (Mont.) Wtr., 5s, 1913 Great Falls (Mont.) Wtr., 5s, 1918 Great Falls (Mont.) 4s, 1923 Great Falls (Mont.) 6s, 8 yrs Great Falls (Mont.) Sch. Dis., 4s, 1925 Harlem (Mont.) Wtr., 6s, 1921-31 Helena (Mont.) Ref., 4s, 1916 Helena (Mont.) Wtr. Wks., 5s, 1931 Helena (Mont.) Sch. Dis., 41/2S, 1922 Kalispell (Mont.) 6s, 1921 Lincoln Co. (Mont.) Rd., 5s, 1927-32 NEBRASKA Beatrice (Neb.) 4s, 1914 Dodge Co. (Neb.) Ref., 4s, 1919 Dodge Co. (Neb.) Frem't Prct., 4s, 1919 Douglas Co. (Neb.) 4s, 1918 Douglas Co. (Neb.) 3^/43, 1922 Grand Island (Neb.) 4l^3, 1925 Johnson (Neb.) 6s, Ser. 1917-27 Lincoln (Neb.) 5s, 1913-14 Lincoln (Neb.) 41/28, 1913-19 'Quotation nearest March 1, 1913. No quotation on that date. 1174 Low Bid Asked 98 99 96 96 971/4 9SVz lOOi/s 93 3^ 94 96 971/2 96 97 99% 103 1001/2 1001/2 10014 1001/2 1001/4 1001/3 1001/4 1021/2 10014 1001/2 41/8% basis 41/8% basis __ *100 *4.70% basis __ *101% 100 — 1031/2 100 100 *102 4.70% basis 4.70% basis 4%% basis __ *100 4.70% basis 100 __ *104.22 __ *104.22 4.70% basis 4.70% basis 4.70% basis __ *100 4.65% basis *5i/2% basis 99 100 4%% basis 4.70% basis __ *100 *4.70% basis 4.90% basis 414% basis 4.70% basis 4.40% basis 4.40% basis 4.80% basis •514% basis 4%% basis 41/3% basis NEBRASKA (Continued). Lincoln (Neb.) Ref., 41/28, 1920-29 Lincoln (Neb.) Ref., 4s, 1919 Lincoln (Neb.) Sch. Dis., 41/28, 1924 Omaha (Neb.) 41/2-8, 1914-21 Omaha (Neb.) Ren'l, 41/38, 1924 Omaha (Neb.) 41/38, 1932 Omaha (Neb.) Ref., 41/38, 1934 Omaha (Neb.) Wtr. Wks., 41/38, 1941 Omaha (Neb.) Funding, 4s, 1918 Omaha (Neb.) Sch. Dis., 41/28, 1928 Omaha (Neb.) Sch. Dis., 4s, 1931 Omaha (Neb.) Sch. Dis., 4s, 1919 Omaha (Neb.) Sch. Dis., 41/2S, 1929-31 Omaha (Neb.) Sch. Dis., 41/38, 1933 Omaha (Neb.) Sch. Dis., 41/28, 1941 South Omaha (Neb.) 5s, 1915 South Omaha (Neb.) 41/38, 1924 South Omaha (Neb.) Sch. Dis., 5s, 1929 South Omaha (Neb.) Sch. Dis., 5s, 1923 Winnebago (Neb.) Wtr. 58, 1917-32 Wymore (Neb.) 58, 1931 NEVADA. Reno (Nev.) 5s, 1924 Yerington (Nev.) 'Sewer, 6s, 1922-27 NEW HAMPSHIRE New Hampshire, Hosp., 31/oS, 1913-25 Bethlehem (N. H.) 48, 1923 Berlin (N. H.) 48, 1917 Concord (N. H.) 4s, 1923 Concord (N. H.) 31/38, 1924-29 Dover (N. H.) 31/38, 1928-31 Dover (N. H.) 4s, 1913-16 Keene (N. H.) 4s, 1914-17 Keene (N. H.) Wtr., 31/3S, 1913 Laconia (N. H.) 4s, 1924 Laconia (N. H.) 4s, 1932 Laconia (N. H.) 43, 1934 Laconia (N. H.) 4s, 1937 Manchester (N. H.) 5s, 1913 Manchester (N. H.) 41/28, 1913 Manchester (N. H.) Wtr., 4s, 1917 Manchester (N. H.) Fund, 31/38, 1919 Manchester (N. H.) 48, 1914 Nashua (N. H.) 4s, 1913-15 Nashua (N. H.) 3s, 1923 Portsmouth (N. H.) 4s, 1914 Portsmouth (N. H.) Sch., 4s, 1923 Portsmouth (N. H.) Wtr., 4s, 1932 Rochester (N. H.) 4s, 1922 Somersworth (N. H.) 4s, 1913-18 NEW JERSEY Asbury Park (N. J.) 58, 1924 Atlantic City (N. J.) 5s, 1925 Atlantic City (N. J.) Wtr., 41/3S, 1926 *Quotation nearest March 1, 1913. No quotation on that date. 1175 High Low Bid 4%% - 4%% - 41/3% __ 4i/3-.40% __ 4i/2-.40% __ 4i/3-.40% __ 4i/2-.40% __ 4i/2-.40% __ 4i/2-.40% 4.40% 4.40% 4.40%, _- *4.40% 4.65%, 4.65% 4.65%, 4.65% Asked basis basis basis basis basis basis basis basis basis basis basis basis *100 *100 basis basis basis ^100 1011/3 100 __ *103.81 97 98 100 95 92 99 99 98 100 99 *98% 98 93 *99 *99i/3 ^973/4 101 1001/3 _. 99 94 100 99 89 99 99 981/3 98 98 4.35% basis 4.30% basis 4.30% basis NEW JERSEY (Continued). Atlantic City (N. J.) 41/28, 1945 Atlantic City (N. J.) Wtr., 4s, 1930 Atlantic Highlands (N. J.) Swr., 4s, 1928 Bayonne (N. J.) Fund, 5s, 1928 Bayonne (N. J.) Fund, 41/28, 1931 Bayonne (N. J.) Fltg. Dbt., 4s, 1928 Belleville (N. J.) 41/2S, 1927-42 Belleville (N. J.) 41/2S, Ser. 1927-42 Belleville (N. J.) 41/2S, 1942 Belmar (N. J.) Wtr., 5s, 1942 Bergen Co. (N. J.) 41/38, 1915-39 ._._ Bergen Co. (N. J.) 41/38, 1917-88 Bergen Co. (N. J.) Bdge., 4s, 1913-24. Bergen CO. (N. J.) Ct. Hse., 4s, 1914-38 Bergen Co. (N. J.) 41/2S, 1915 Bergen Co. (N. J.) 41/2S, 1932 Bergenfield (N. J.) 58, 1913-24 Bernards (N. J.) 5s, 1929-30 Bridgeton (N. J.) Wtr. 41/2S, 1943 Camden (N. J.) Wtr., 41/28, 1923_ Camden (N. J.) Dock, 41/28, 1930 Camden (N. J.) Paving, 48, 1929 Camden (N. J.) 31/2S, 1913-34 Camden Co. (N. J.) 4s, 1944 Camden (N. J.) Sch., 41/28, 1943 Cape May (N. J.) 5s, 1934 Cap May Co. (N. J.) Rd., 58, 1943 East Orange (N. J.) 48, 1934 East Orange (N. J.) Wtr., 4s, 1933 East Orange (N. J.) Wtr., 31/2S, 1933 Edgewater (N. J.) 41/2S, 1915 Edgewater (N. J.) 5s, 1914-36 Elizabeth (N. J.) 48, 1922 Englewood (N. J.) 4s, 1935 Essex Co. (N. J.) 48, 1926 Essex Co. (N. J.) Pk., 4s, 1938 Essex Co. (N. J.) Hosp., 4s, 1946 Essex Co. (N. J.) Pk., 3.65s, 1935 Essex Co. (N. J.) 3.658, 1915 Ft. Lee (N. J.) 5s, 1917-25 Guttenberg (N. J.) Ref., 58, 1913-18 Hackensack (N. J.) 41/2S, 1942 Harrison (N. J.) 48, 1930 Harrison (N. J.) 41/2S, 1936 Hoboken (N. J.) 4s, 1919 Hoboken (N. J.) 41/38, 1940 Hoboken (N. J.) 31/28, 1931 Hoboken (N. J.) Wtr., 4s, 1939 Hoboken (N. J.) 4s, 1918 Hudson Co. (N. J.) Rd., 41/28, 1953-63 Hudson Co. (N. J.) 41/38, 1948 Hudson Co. (N. J.) Rd., 41/2S, 1923 Hudson Co. (N. J.) Pk., 41/28, 1950 Hudson Co. (N. J.) Pk., 4s, 1954 Hudson Co. (N. J.) Pk. 48, 1959 Hudson Co. (N. J.) Co. Bldgs., 4s, 1946 Hudson Co. (N. J.) Ref., 4s, 1935 •Quotation nearest March 1, 1913. No quotation on that date. 1176 High Low Bid 4.30% 4.30% 4.40% 4.30-.20% 4.30-.20% 4.30-.20% *4.30% Asked basis basis basis - 41/4% - 4.35-.25% - 41/4% - 41/4% •4.60% *4.38% basis basis * 102% basis *102i/3 *10Gi/3 basis basis basis basis *101 *104 basis basis __ *102 4*A% basis 414% basis 4l^% basis 4iA% basis 4iA% basis — *104% 4.60% basis ._ n02i/4 4.30% basis 4.30 %ba8i8 4.30% basis — *10134 *4.45% basis 971/2 991/2 4.30% basis 4l^%basis 41/8% basis 414% basis 4%% basis __ *99 ♦41/3% basis 5% basis 4.40% basis 4.30% basis — •1031/g 414% basis 414% basis 414% basis — *98y4 *4.30% basis •4.30% basis 4:20% basis 4.20% basis 4.20% basis 4.20% basis 4.20% basis 4.20% basis 4.20% basis NEW JERSEY (Continuea). Hudson Co. (N. J.) Bridge, Sy^s, 1920 Jersey City (N. J.) Wtr., 7s, 1913 Jersey City (N. J.) 7s, 1913 Jersey City (N. J.) Assess., 5s, 1924 Jersey City (N. J.) Wtr., 5s, 1921 Jersey City (N. J.) Assess., 5s, 1916 Jersey City (N. J.) Wtr., 5s, 1916 Jersey City (N. J.) Ref., 41/38, 1928 Jersey City (N. J.) Sch., 41/28, 50 yrs Jersey City (N. J.) Wtr., 41/2S, 1961 Jersey City (N. J.) Sch., 41/4S, 1961 Jersey City (N. J.) Pk., 41/4S, 1961 Jersey City (N. J.) Wtr., 4s, 1932 Jersey City (N. J.) 4s, 1935 Jersey City (N. J.) Ref., 4s, 1949 Jersey City (N. J.) Ref., 31/aS, 1920 Kearny (N. J.) 41/28, 1936 Kearny (N. J.) 41/2S, 1962 Lodi (N. J.) Wtr., 5s, 1939 Long Branch (N. J.) 4s, 1935 Mercer Co. (N. J.) 41/38, 1933 Mercer Co. (N. J.) Rd., 48, 1933 Mercer Co. (N. J.) 31/38, 1941 Middlesex Co. (N. J.) Bridge, 1922-31 Montclair (N. J.) Sch., 41/3S, 1941 Montclair (N. J.) Sch., 31/3S, 1932 Morris Co. (N. J.) 4s, 1935 Morris Co. (N. J.) 41/38, 1942 Newark (N. J.) 4s, 1941 Newark (N. J.) Wtr. 41/38, 1915 Newark (N. J.) Ref. 4s, 1923 Newark (N. J.) Sch. 48, 1959 Newark (N. J.) Pas. Vy. Sr. 4s, 1961 Newark (N. J.) 31/3S, 1929 Newark (N. J.) Trk. El. 31/3S, 1954___ Newark (N. J.) Sch. 3.35s, 1917 New Brunswick (N. J.) 4s, 1922 North Bergen (N. J.) 53, 1941 Nutley (Neb.) 41/3S, 1922-32 Nutley (Neb.) 41/3S, 1942 Orange (N. J.) 5s, 1923-32 Orange ( N. J.) Wtr. 5s, 1938 Orange (N. J.) Swr. 41/38, 1915-21 Orange (N. J.) Sch. 43, 1934 Orange (N. J.) 41/38, 1931 Passaic (N. J.) 41/3S, 1914-40____ Passaic (N. J.) Sch. 41/38, 1942 Passaic (N. J.) 31/3S, 1913-20 Passaic Co. (N. J.) 4s, 1920-24 Paterson (N. J.) 58, 1913-22 Paterson (N. J.) 41/3S, 1933-44 Paterson (N. J.) N. C. H'l. 43, 1923-32 Paterson (N. J.) 41/3S, 1914 Paterson (N. J.) 41/38, 1939 Paterson (N. J.) 41/3S, 1942 Perth Amboy (N. J.) 41/38, 1922 Perth Amboy (N. J.) Sch., 41/3S, 1938 •Quotation nearest March 1, 1913. No quotation on that date. 1177 High Low Bid Asked 4.20% basis 414% basis 4iA% basis 4.20% basis 4.20% basis 4.20% basis 4.20% basis 4.20% basis *102.531 __ 4.20% basis 4.20% basis 4.20% basis 4.20% basis 4.20% basis 4.20% basis 4.20% basis 4.30% basis 4.30% basis _. *107% 4.30% basis __ 102.65 414% basis 414% basis 4V4% basis 4l^% basis 4.20% basis 4.15% basis 4.15% basis - *99i/3 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.15% basis 4.30% basis 41/3% basis *4.40% basis __ *102i/4 4.30% basis 4.30% basis 4.30% basis 4.30% basis ♦414% basis 41/4% basis 414% basis 4i/t% basis 4l^% basis 414% basis 4iA% basis 414% basis *4.40% basis __ *103.15 *4i^% basis 414% basis 4l^% basis NEW JERSEY (Continuea). High Low Bid Asked Plainfield (N. J.) 4s, 1913-34 __ __ 41/4% basis Plainfield (N. J.) Sch., 4s, 1959 __ __ 41/4% basis Rahway (N. J.) Adj, 4s, 1922 __ __ 90 95 Red Bank (N. J.) Wtr., 5s, 1914 __ __ *4.40% basis Ridgewood (N. J.) 5s, 1013-26 __ __ 4.35% basis South Amboy (N. J.) Sewer, 5s, 1928-32 __ __ *4.55% basis South Orange (N. J.) 4s, 1913-44 __ __ 4.30% basis Summit (N. J.) Sch., 41/2S, 1941 __ __ 414% basis Summit (N. J.) 4s, 1933 __ __ 414% basis Trenton (N. J.) 4y2S, 1941 __ __ 4l^% basis Trenton (N. J.) Fund., 4s, 1934 __ __ 414% basis ■ Trenton (N. J.) City HI., 4s, 1939 __ __ 4^4% basis Trenton (N. J.) Sch., 31/28, 1929 __ __ 4l^% basis Trenton (N. J.) 4s, 1917 __ __ __ *99 Trenton (N. J.) 41/2S, 1943 __ __ 4^4% basis Union Co. (N. J.) 41/28, 1937 __ __ 1031/3 103% Union Co. (N. J.) 41/38, 1942 __ __ 1033/3 104l^ Union Co. (N. J.) 4s, 1942 __ __ 4.20% basis Vailsburg (N. J.) Swr., 41/2S, 1934 __ __ 4.15% basis Weehawken (N. J.) Fdg., 41/2S, 1920 __ __ 4.30% basis Weehawken (K J.) Fdg., 41/2S, 1913-28 __ __ 4.30% basis West New York (N. J.) Sch., 68, 1945-59 __ __ __ *106 Wildwood (N. J.) 5s, 1943 __ __ __ *106.125 NEW MEXICO New Mexico Ref., 6s, 1923 __ — 41/2% basis New Mexico 6s, 1913-17 __ __ 5-41/2 %j basis New Mexico 41/2S, 1916-52 __ __ 101 101.60 New Mexico Ref., 4s, 1937 — — 4.40% basis New Mexico Bldg., 4s, 1929 __ __ 41/2% basis New Mexico Fund., 4s, 1939 __ __ 4.40% basis Alburquerque (N. M.) 41/2S, 1929 _» __ 4.60% basis Alburquerque (N. M.) 5s, 1933-43 __ __ __ *104.35 Bernalills Co. (N. M.) Fund., 6s, 1922 __ __ 100 Bemalills Co. (N. M.) 5s, 1931 __ „ 4%% basis Portales (N. M.) Wtr. & Sewer, 6s, 1927-39— — — *4.80% basis Socorro Co. (N. M.) 5s, 1931 __ __ 4.80% basis NEW YORK New York Can. Term., 4s, 1942 __ __ 1001/2 lOlVa New York High. Imp., 48, Mar. 1958 __ __ lOli/g __ New York High. Imp., 4s, Sept. 1958 __ __ lOli/g — New York High. Imp., 4s, 1960 __ __ 101 New York Can. Imp., 4s, 1960 ._ >_ lOli/g — New York Can. Imp., 4s, Jan. 1961 __ — lOlVs 1021/3 New York Can. Imp., 4s, July 1961 __ __ IOI1/2 — New York Can. Imp., 48, 1962 — — lOiy^ __ New York High. Imp., 4s, 1961 __ __ lOlVs _- New York High. Imp. 4s, 1962 __ __ IOI1/2 — New York 3s, 1923 __ __ 97i/a — New York 3s, 1956 ,_ __ 971/2 __ New York 3s, 1958 __ __ 971/2 — New York Canal, 3s, 1959 __ __ 971/2 __ New York Canal, 4s, 30 yrs __ __ *100.026 __ Albany (N. Y.) 6s, 1915-19 __ __ 4l^-.15% basis *QuotatiOD nearest March 1, 1913. No quotaUon on that date. 1178 NEW YORK (Continued). Albany (K Y.) Wtr., 41/48, 1932 Albany (N. Y.) Pk., 4s, 1920-30 ■- Albany (N. Y.) Sch., 4s, 1914-31 Albany (N. Y.) Imp., 31/28, 1914-24 Albany (N. Y.) 4s, 1922 Albany Co. (N. Y.) 31/38, 1913-25 Albany Co. (N. Y.) 31/3S, 1925 Albion (N. Y.) Sewer, 4.65s, 5-29 yrs Altamount (N". Y.) 5s, 1913-15 Argyle (N. Y.) 4.40s, 1929-41 Auburn (N. Y.) 41/2S, 1913-31 Auburn (N. Y.) Wtr., 4s, 1914-25 Bloomingdale (N. Y.) 4.65s, 1930-42 Binghampton (N. Y.) 4s, 1928-29 Binghampton (N. Y.) Bdge., 31/3S, 1935 Brooklyn (N. Y.) 31/38, 1934 Brooklyn (N. Y.) 31/08, 1936 Brooklyn (N. Y.) Bdge., 3s, 1925 Brooklyn (N. Y.) 7s, 1915 Brooklyn (N. Y.) 6s, 1924 Brooklyn (N. Y.) Bdge., 5s, 1919 Brooklyn (N. Y.) Bdge., 4s, 1926 Brooklyn (N. Y.) Sch., 4s, 1920 Brooklyn (N. Y.) Wtr., 4s, 1914 Brooklyn (N. Y.) 31/38, 1914-37 Brooklyn (N. Y.) 31/38, 1925 Brooklyn (N. Y.) 31/38, 1927 Buffalo (N. Y.) 4s, 1960 Buffalo (K Y.) 31/38, 1917 Buffalo (N. Y.) Pk., 31/38, 1927 Buffalo (N. Y.) 31/3S, 1913-19 Buffalo (N. Y.) Wtr., 31/38, 1913-35 Buffalo (N. Y.) Road, 3s, 1913 Buffalo (N. Y.) 41/48, 1932 Buffalo (N. Y.) 7s, 1924-35 Buffalo (N. Y.) Pk., 6s, 1924 Buffalo (N. Y.) 41/48, 1962 Buffalo (N. Y.) Swr., 4s, 1913 Buffalo (N. Y.) Sch., 4s, 1929 Buffalo (N. Y.) 4s, 1913-29 Buffalo (N. Y.) 4s, 1913-30 Buffalo (N. Y.) 48, 1931-61 Cheektowaga (N. Y.) 58, 1914-42 Cohoes (N. Y.) 7s, 1913 Cohoes (N. Y.) 4s, 1920 Cortlandt (N". Y.) 4.10s, Ser. 1914-45 East Syracuse (N. Y.) 41/38, 1917-18 Elmira (N. Y.) 4s, 1935 Elmira (N. Y.) 31/38, 1913-21 Elmira (N. Y.) 41/38, 18% yrs Elmira (N. Y.) 41/38, Ser. 1 to 3 yrs Erie Co. (N. Y.) Road 41/4 s, 1915-36 Evans (N. Y.) Sch., 4.608, 1918-47 Fallsburg (N. Y.) 58, 1925-31 Far Rockaway (N. Y.) Imp., Ss, 1913-21 Franklin Co. (N. Y.) 41/33, 1931-40 Fulton (N. Y.) 3.40s, 1913-29 *QuotatioD nearest March 1, 1913. No quotation on that date. 1179 High Low Bid Asked __ 4 1^ -.15% basis __ 4i/4-.15% basis __ 4l^-.15% basis __ 4l^.20% basis — *9834 __ 4l^-.15% basis __ 4i4-.15% basis *100.10 — _- *4i/3% basis __ *100 — 4.30-1/4% basis __ 4.30-14% basis __ *4.40% basis __ 4.20-.15% basis __ 4.20-.15% basis __ 4.35-.30% basis __ 4.35-.30% basis __ 4.35-.30% basis __ *4.35% basis __ 4.35-.30% basis __ 4.35-.30% basis __ 4.35-.30% basis __ 4.35-.30% basis _- 4.35-.30% basis __ 4.35-.30% basis __ 4.35-.30% basis __ 4.35-.30% basis __ 4l^-.15% basis __ 4l^-.15% basis __ 4l^ -.15% basis -_ 41/41.15% basis — 4l^-.15% basis __ 4iA-.15% basis _- *100% __ 41/4 -.15% basis — 4i/4-.15% basis -_ 4l^-.15% basis __ 4V4-.15% basis __ 4i4-.51% basis __ 414 -.15% basis __ 4l^-.15% basis __ *993/4 __ *4.38% basis __ 4i/i-.20% basis __ 4l^-.20% basis __ *100 -_ *4.35% basis _- 4i4-.20% basis __ 4l^-.20% basis *102.80 _- *100 4i4-.15% basis __ *4.375% basis __ *4i/3% basis __ 4.35-14% basis __ 4.35-.20% basis __ 4.30-.20% basis • NEW YORK (Continued). High Low Bid Asked Geneva (N. Y.) Wtr., 4g, 1926 — — 4.30-.20% basis Glens Falls (N. Y.) Swr., 41/28, 1917-28 ._ _- 41/4% basis Gloversville (N. Y.) 31/28, 1917 — — 4l^-.20% basis Haverstraw (N. Y.) 4.12s, 1913-27 — — 4.35-.20% basis Harrison (N. Y.) 41/2S, 1914-65 — — *4.30% basis Hempstead (N. Y.) 4s, 1923 __ — 4.35-1/4% basis Hempstead (N. Y.) 41/38, 1918-20 _- — — *100% Herkimer (N. Y.) 41/2 8, 1912-27 — __ 4.35-.20% basis Hornellsville (N. Y.) 31/38,1921 — — 4.30-.20% basis Honeoye Falls (N. Y.) Wtr., 4.90s, I71/4 yrs-_ ._ __ __ *100.44 Interlaken (N. Y.) 4.60s, 91/2 yrs __ — — *100.17 Hudson (N. Y.) Wtr., 48, 1913-22 — 4.35-.20% basis Ithaca (N. Y.) 4.30s, 1927 — __ 4.30-.20% basis Ithaca (N. Y.) Wtr., 41/4S, 1942 — — 99 100 Jamaica (N. Y.) 4s, 1917 — — 4.30-1/4% basis Jamestown (N. Y.) 48, 1943 — __ 4.35-.20% basis Kings Co. (N. Y.) Pk., 4s, 1913-44 — — 4.30- .20% basis Kingston (N. Y.) 31/2S, 1913-36 _ 4i4-.15% basis Kingston (N. Y.) Ref., 38, 1914 __ — ^y^-,15% basis La Salle (N. Y.) 4.70s, 1924-41 __ __ *4.40% basis Lackawanna (N. Y.) 41/2S, 1927-29 __ — •4.30%; basis Larchmont (N. Y.) 4.75s, 5 to 18 yrs __ — *100.20 — Larchmont (N. Y.) 4.75s, 1918-31 „ — *4.40% basis Locke (N. Y.) 4.80s, 1914-33 — __ *4.40%j basis Long Island City (N. Y.) 6s, 1914-19 __ _-4.30-.20%, basis Long Island City (N. Y.) 41/28, 1913-23 __ — 4.30-.20%, basis Long Island City (N. Y.) Wtr., 4s, 1920 __ „ 4.30-.20% basis Long Island City (N. Y.) Wtr., 31/28, 1920__ — >_ 4.30- .20% basis Lysander (N. Y.) 41/28, 1914-35 __ __ *4.40% basis Malone (N. Y.) 4.30s, 1913 __ — *100 Mayville (N. Y.) 4.60s, 1932-42 — __ •4.40%) basis Middleport (N. Y.) 4.35s, 1915-42 __ __ 4.30-.20% basis Middleport (N. Y.) Swr., 4.35s, 1913-39 __ __ 4.30-.20% basis Middletown (N. Y.) 31/2S, 1931 __ __ 4.30-.20% basis Middletown (N. Y.) 41/3S, 1933 _. __ __ ^104 Mt. Vernon (N. Y.) 41/oS, 1931-43 __ __ 4.30-.20%, basis Mt. Vernon (N. Y.) Swr., 4s, 1950-55 __ __ 4.30-.20% basis Mt. Vernon (N. Y.) Sch., 41^8, 1962-73 __ __ 99 100 Mt. Vernon (N. Y.) 41/38, 1933 __ __ __ ^102% Mt. Vernon (N. Y.) 41/38, 1952 „ „ •41^%, basis Mt. Vernon (N. Y.) 41/38, 1960-61 __ — __ •104l^ Mt. Vernon (N. Y.) 41/38, 1964-65 __ __ __ •99iA Nassau Co. (N. Y.) 41/3S, 1920-29 _. __ 4.30-.20% basis Nassau Co. (N. Y.) Ct. Hse., 31/38, 1930 „ __ 4.30-.20% basis New Berlin (N. Y.) 4s, 1939-44 __ __ __ •lOO Newburgh (N. Y.) 41/2S, 1914-34 -_ «_ 4l^% basis Newburgh (N. Y.) 3.85s, 1929 __ __ __ *96 New Rochelle (N. Y.) 41/2S, 1915-22 ._ __ 4.30-iA%, basis New Rochelle (N. Y.) 4s, 1913-30 __ __ 4.35-l^% basis New Rochelle (N. Y.) 31/2S, 1913-33 »_ __ 4.35-1/4% basis N. Y. City Stk., 31/38, 1953 __ __ 831/3 84% N. Y. City Stk., 31/2S, May 1954 .. _. 841/4 86 N. Y. City Wtr., 31/28, 1954 __ __ 83% 84% N. Y. City Stk., 31/38, Apr. 1954 .. __ 83% 84% N. Y. City Stk., 31/38, 1955 __ __ 833/4 84% N. Y. City 31/2S, 1929 __ __ 4.40-.30% basis N. Y. City Co., 3.30s, 1917-21 __ ' ._ 4.40- .30% basis 'Quotation nearest March 1, 1913. No quotation on tliat date. 1180 NEW YORK (Continued). High N. Y. City Sch., 3s, 1913 N. Y. City 41/28, (old) May, 1957 N. Y. City 41/28, (new) Nov. 1957 104 N. Y. City 41/2S, (old) May 1917 101 N. Y. City iVoS, (new) Nov. 1917 N. Y. City 41/48, Mar. 1960 99% N. Y. City 4l^s, Sept. 1960 N. Y. City 414s, Mar. 1962 N. Y. City 48, 1913 N. Y. City 31/2S, 1915 N. Y. City 31/2S, 1932 N. Y. City Bklyn., 31/38, 1927 N. Y. City Dk., 3148, 1927 N. Y. City 31/28, 1941 N. Y. City 31/2S, 1942 - N. Y. City E. T., 31/2S, 1948-50 N. Y. City 31/2S, 1952 N. Y. City 4s, 1913-36 N. Y. City 48, 1955 N. Y. City 4s, 1913-56 N. Y. City Stk., 4s, 1957 N. Y. City Stk., 4s, 1958 N. Y. Citv Stk., 4s, 1959 — 96i/8 N. Y. City 31/2S, 1914 N. Y. City Pk., 31/2S, 1916 N. Y. City Str., 3s, 1916 N. Y. City Dk., 3s, 1924 N. Y. City R. T., 3s, 1950 N. Y. City Pk. 21/2S, 1929 N. Y. City 31/28, 1914 N. Y. City 31/2S, 1940 Niagara Falls (N. Y.) 4s, 1921 Niagara Falls (N. Y.) 31/2S, 1942-45 No. Daneaville (N. Y.) S. D., 58, 1913-28 North Elba (N. Y.) Sewer, 5s, 5 to 24 yrs No. Hempstead (N. Y.) 4.60s, 1913-33 Ossining (N. Y.) 4.40s, 171/2 yrs North Tonawanda (N. Y.) 4s, 1924 Pelham (N. Y.) 41/2S, 1917-30 Pelham (N. Y.) Sch., 41/2S, 1919-52 Oneida Co. (N. Y.) 31/2S, 1914-28 Onandago Co. (N. Y.) 3s, 1913-29 Orange Co. (N. Y.) 31/2S, 1915-24 Oswego (N. Y.) 31/2S, 1913-23 Penn Yan (N. Y.) 4.35s, 1913-31 Poughkeepsie (N. Y.) 7s, 1913 Poughkeepsie (N. Y.) Sch., 41/28, 1922 Poughkeepsie (N. Y.) 31/38, 1913-30 Poughkeepsie (N. Y.) 41/2S, 10 yrs Port Chester (N. Y.) 5s, 1-3 yrs Port Chester (N. Y.) 5s, 1918 Port Chester (N. Y.) 41/2S, 1915-29 Port Chester (N. Y.) 5s, 1929-40 Portville (N. Y.) 5s, 1914-18 Putnam Co. (N. Y.) 41/2S, 1918-29 Queens Co. (N. Y.) 48, 1917 Queens Co. (N. Y.) 4s, 1927 *Quotatioo nearest March 1, 1913. No quotation on that date. 1181 Low Bid Asked __ 4.40-.30% basis 1031/2 104 104 101 101 102 99% _- - 99% 100 98% 98% __ 4.35-14% basis __ 4.40-.30% basis __ 4.40-.30% basis __ 4.40-.30% basis __ 4.40-.30% basis 851/2 86% 851/2 86% 831/2 - 831/2 94 94 96 96 8434 84% 96 96 96 961/4 961/4 96% - - __ 4.40-.30% basis __ 4.40-.30% basis __ 4.40-.30% basis __ 4.40-.30% basis __ 4.40-.30% basis 4.45% basis __ *4.30% basis __ *4.35% basis 4.30% basis 4.30% basis __ 4.35-14% basis *100i/2 - __ *4.30% basis *100.315 __ 4.40% basis __ *4.40% basis _- *4.35% basis __ 4.30-.20% basis 4.30% basis __ 4.30-.20% basis __ 4.30-.20% basis __4.30-.20% basis __ 4i4-.20% basis — 4i4-.20% basis __ 4i4-.20% basis *101.73 — *100.07 — *4.45% basis _- *4.35% basis __ *4.35% basis __ *4.40% basis _. 4i4-.20% basis __ 4 1/4 -.15% basis __ 4i4-.15% basis NEW YORK (Continuea). Richmond Co. (N. Y.) Fund., 4s, 1914 Richmond Co. (N. Y.) 4s, 1921 Rochester (N. Y.) 4s, 1922-27 Rochester (N. Y.) Ref., sy^s, 1914 Rochester (N. Y.) Imp., SVgS, 1919 Rochester (N. Y.) Imp., 3i/oS, 1924 Rochester (N. Y.) Ref., sy^s, 1933 Rochester (N. Y.) Edge., 3l^s, 1921 Rockland Co. (N. Y.) 4s, 1913-34 Rockland Co. (N. Y.) Fd., 31/2S, 1914-24 Rome (N. Y.) 414s, 1931 — - Rye (N. Y.) 5s, 1913-38 Saranac Lake (N. Y.) 4y2S, 1917-26 Saranac Lake (N. Y.) 4.45s, 1915-30 Saratoga Co. (N. Y.) Rd., 5s, 1914-18 Saratoga Spgs. (K Y.) Pk., 4y4S, 1916-40 Schenectady Co. (N. Y.) 4y2S, 1943-45 Schenectady (N. Y.) 4y28, 1913-31 Schenectady (N. Y.) Mkt., 4y4S, 1913-31 Schroeppel (N. Y.) 4y2S, 1923-27 Schuyler (N. Y.) 3s, 1916-40 Silver Springs (N. Y.) 4.80s, 1917-30 Southampton (N. Y.) 4y2S, 1914-20 Solvay (N. Y.) 4y2S, 1916-40 Syracuse (N. Y.) Wtr., 4s, 1920 Syracuse (N. Y.) Ref., 4s, 1929 Syracuse (N. Y.) Wtr., 3y2S, 1928 Syracuse (N. Y.) Wtr., 38, 1920 Troy (N. Y.) 4y2S, 1913-25 Troy (N. Y.) Sch., 4y2S, 1913-31 Troy (N. Y.) Wtr., 3y2S, 1916-36 Troy (N. Y.) Wtr., 4s, 1915-25 Troy (N. Y.) 4y2S, 1937-42 Utica (N. Y.) 4s, 1914-19 Utica (N. Y.) 31/38, 1913-35 Watertown (N. Y.) 4y2S, 1942 Watertown (N. Y.) 4s, 1938 Watertown (N. Y.) Swr., 3y2S, 1913-27 Westchester Co. (N. Y.) 3y2S, 1927-28 Westchester Co. (N. Y.) 4s, 1930-35 Westchester Co. (N. Y.) Swr., 4y2S, 1933-38__ Westchester Co. (N. Y.) 3.10s, 1913-14 West Seneca (N. Y.) 5s, 1913-38 West Seneca (N. Y.) 5s, 1929-31 White Plains (N. Y.) 4s, 1914-28 White Plains (N. Y.) 3y2S, 1931 White Plains (N. Y.) 31/28, 1913-14 Whitehall (N. Y.) 5s, 1913-27 Wolcott (N. Y.) 41/28, 1931 Yonkers (N. Y.) 4s, 1914-25 Yonkers (N. Y.) Wtr., 4s, 1913-22 High Low Bid Asked __ 414 -.20% basis __ 414 -.20% basis __ 4.30-14% basis __ 4.30-14% basis __ 4.30-14% basis __ 4.30-14% basis __ 4.30-14% basis __ 4.30-14% basis __ 4.35-.20% basis __ 4.35-.20% basis __ 4.35-.20% basis __ 4.30-.20% basis __ 4.35-20% basis __ 4.35-.20% basis __ 4.35-.20% basis __ 4.35-.20% basis __ *4i4% basis __ 4.30-.20% basis __ 414 -.20% basis __ *4.375% basis __ *4.40% basis __ *4i/2% basis __ •1001/2 -- 414% basis __ 4.30-.20% basis __ 4.30-.20% basis __ 4.30-.20% basis __ 4.30-.20% basis __ 4.40-.30% basis __ 4i4-.30% basis __ 4i4-.30% basis __ 4i4-.30% basis __ *4.20% basis __ 4.30-.20% basis __ 4.30-.20% basis __ 102 __ 4.30-.20% basis __ 4.30-.20% basis __ 4.30-.20% basis __ 4.30-.20% basis __ 414 -.20% basis *98% _- __ 4.35-14% basis __ *109.84 __ 4.35-.20% basis __ 4.35-.20% basis __ *4.40% basis __ *4.40% basis __ 4.30-.20% basis __ 4.30-.20% basis __ 4.35-.20% basis NORTH CAROLINA North Carolina Constr., 6s, 1919 North Carolina Ref., 4s, 1950 North Carolina Bldg., 4s, 1951 *QuotatioD nearest March 1, 1913. No quotation on that date. 1182 109 99 100 111 101 101 NORTH CAROLINA (Continued). High Low Bid Asked Albemarle (N. C.) 5s, 1943 , — — — *104 Asheville (N. C.) Swr. & Wtr., 6s, 1918 __ __ 4.60% basis Asheville (N. C.) Ref., 5s, 1941 — __ 4.70% basis Asheville (N. C.) 1943 — — *4.73% basis Beaufort Co. (N. C.) 5s, 1937 — — — *105 Buncombe Co. (N. C.) 5s, 1931 — __ 4.60% basis Buncombe Co. (K C.) Fdg., 4y2S, 1939 — — — 100 Burlington (K C.) Wtr., 5s, 1938 __ — — *105i4 Carthage (K C.) Wtr. & Sewer, 51/38, 1943 __ __ __ *107.73 Cleveland Co. (N. C.) Rd., 5s, 1933-37 — — — *100 Charlotte (N. C.) St. & 'Swr., 5s, 1939 __ __ 4%-y2% basis Charlotte (N. C.) Wtr., 4%s, 1935 __ __ 4%-.40% basis Charlotte (N. C.) Wtr., 41/38, 1941 __ __ 4%-.40% basis Charlotte (N. C.) Sch., 41/38, 1941 __ __ 4%-.40% basis Charlotte (N. C.) 41/38, 1943 __ __ 99 101 Durham (N. C.) Swr. & St., 41/38, 1941 __ __ 98 101 Durham (N. C.) Sch., 5s, 1933 __ __ *4i/3% basis Gastonia (N. C.) 5s, 30 yrs __ __ *101.61 __ Granville Co. (N. C.) 41/3S, 1939 __ __ 98 Greensboro (N. C.) Wtr., 5s, 1930 __ __ IO31/0 __ Greensboro (N. C.) Wtr., 4s, 1954 __ __ 85 "^ 90 Greenville (N. Y.) 5s, 1937 __ __ 103 105 Guilford Co. (N. C.) 5s, 1^33 __ __ __ 110 Iredell Co. (N. C.) 5s, 1943 __ __ 4.90-%% basis Iredell Co. (N. C.) 51/38, 3 to 11 yrs __ __ *103.135 __ La winburg (N. C.) 51/38, 1933 __ __ *5%, basis Lee Co. (N. C.) Road, 5s, 1953 __ __ 4.70% basis Mecklenberg (N. C.) 6s, 1930 __ __ 106 108 New Hanover Co. (N. C.) 41/3S, 1936 __ __ 4.30% basis Raleigh (N. C.) 58, 1937 __ __ 104 106V4 Raleigh (N. C.) 4s, 1939 __ __ 90 Rich Square (N. C.) 51/38, 1933-36 __ __ *5% basis Scotland Co. (N. C.) Rd., 6s, 1934-39 __ __ *5i4%, basis Tarboro (N. C.) Wtr., 5s, 1946 __ __ __ *103 Thomasville (N. C.) 5s, 1943 __ __ __ *104 Wilmington (N. C.) Fd., 5s, 1933 __ __ 4%-i/2% basis Wilmington (N. C.) Wtr. & Swr., 41/38, 1948„ __ __ 43/4-.40% basis Wilmington (N. C.) Wtr. & Swr., 41/38, 1953— __ __ 4%-.40% basis Wilmington (K C.) Ref., 4s, 1939 __ __ 90 Winston (N. C.) Imp., 41/38, 1951 __ __ 99 101 Winston (N. C.) 41/38, 1953 __ __ 99 101 NORTH DAKOTA North Dakota Fdg., 4s, 1930-31 __ __ 100 Cavalier Co. (No. Dak.) 6s, 1915-35 __ __ *5i/3% basis OHIO Adams Co. (Ohio) 41^8, 1947 __ __ *3.85% basis Akron (Ohio) Wtr., 4s, 1943 __ __ 3.90% basis Akron (Ohio) 41/3S, 13 yrs __ __ *100.846 „ Akron (Ohio) 41/38, I31/3 yrs __ __ *100.65 — Alliance (Ohio) Elec. Lt. 41/38, 17%-18i/2 yrs. — __ *100.66-100.92 Alliance (Ohio) 41/38, 1937-33 __ __ 3.90% basis Archbold (Ohio) St., 41/2S, 1-10 yrs. »_ __ *100 Ashtabula (Ohio) 48, 1936 __ __ __ *103i4 ♦Quotation nearest March 1, 1913. No quotation on that date. 1183 OHIO (Continued). Auglaize Co. (Ohio) Bldg., 5s, 1913 Avondale (Ohio) 5s, 1916 Barberton (Ohio) Sch., 41/28, 1923-37 Barnesville (Ohio) 5s, 1913-15 - Bellaire (Ohio) Sch., 48, 1923-31 Bellefontaine (Ohio) Sch., 41/38, 1921-34 Bratenahl (Ohio) 41/38, 1919-22 Bowling Green (Ohio) Ref., 58, 1914-17 Butler Co. (Ohio) Bdg., 41/38, 1921-24 Butler Co. (Ohio) 4s, 1914-16 Burton (Ohio) St., 58, 1-4 yrs Cambridge (Ohio) 41/38, 1914-34 Cambridge (Ohio) 48, 1923 Canton (Ohio) 58, 1915-17 Canton (Ohio) Wtr., 41/38, 1930 Canton (Ohio) 48, 1921-27 Canton (Ohio) S. D. 4s, 1917-18 Canton (Ohio) St. & Swr., 41/38, 1916-23 Canton (Ohio) Sewer, 41/38, 1922 Canton (Ohio) Wtr. Swr. & St., 41/38, 1916-32 Carthage (Ohio) 31/38, 1925 Cincinnati (Ohio) 48, 1949-52 Cincinnati (Ohio) Wtr., 31/38, 1945 Cincinnati (Ohio) Ref., 31/3S, 1953 Cincinnati (Ohio) Wtr., 38, 1939 Cincinnati (Ohio) Sch. Dis., 4s, 1936 Cincinnati (Ohio) Sch. Dis., 31/38, 1940 Cincinnati (Ohio) 31/38, 1935-36 Cincinnati (Ohio) 3.658, 1937 Cincinnati (Ohio) 31/28, 1943-65 Cincinnati (Ohio) 58, 1930 Cincinnati (Ohio) 4s, 1934 Cincinnati (Ohio) S. F. 48, 1941 Cincinnati (Ohio) 4s, 1949 Cincinnati (Ohio) 3.65s, 1937 Cincinnati (Ohio) Ref., 31/28, 1956 Cincinnati (Ohio) 31/3S, 1938 Cleveland (Ohio) Libr., 58, 1918 Cleveland (Ohio) Bdge., 4148, 1943 Cleveland (Ohio) Bdge., 4148, 1931 Cleveland (Ohio) Pk., 4l^s, 1938 Cleveland (Ohio) Pvg., 4.108, 1930 Cleveland (Ohio) Swr., 4.108, 1930 Cleveland (Ohio) Ref., 4s, 1918 Cleveland (Ohio) Infirm., 4a, 1930 Cleveland (Ohio) Wtr., 4s, 1930 Cleveland (Ohio) Swr., 4s, 1935 Cleveland (Ohio) Ref., 4s, 1937 Cleveland (Ohio) Pk., 4s, 1939 Cleveland (Ohio) Pk., 48, 1931 Cleveland (Ohio) Swr., 4s, 1919 Cleveland (Ohio) Pk., 43, 1934 Cleveland (Ohio) Gde. Cr., 4s, 1930 Cleveland (Ohio) Sch. Dis., 43, 1933 Cleveland (Ohio) Sch. Dis., 48, 1933 Cleveland (Ohio) Sch. Dis., 41/08, 1930 Cleveland (Ohio) Sch. Dis., 58, 14 5/6 yrs ""Quotaticm nearest March 1, 1013. No quotation on that date. 1184 High Low Bid 3.90% 3.80% *3.90% *4% *3.80% *3.90% *3.90% 4% 3.90% 3.90% *100 4% 4% 3.80% 3.80% 3.80% 3.90% *3.85% *3.90% *3.90% *96i/2% 3.80% 3.80% 3.80% 3.80% 3.80% Asked basis basis basis basis basis basis basis basis basis basis basis basis basis basis basis basis basis basis basis *105 basis basis basis basis basis *96y4 - •941/3 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis •103.30 — OHIO (Continued). Cleveland (Ohio) Sch. Dis., 4s, 1915 Cleveland (Ohio) Wtr., 4s, 1917 Cleveland (Ohio) 5s, 1919 Cleveland (Ohio) St., 4s, 1937-37 Cleveland (Ohio) 4s, 1942 Clifton (Ohio) Wtr., 41/28, 1913-22 College Hill (Ohio) Wtr., 31/38, 1929 Columbiana Co. (Ohio) Rd. 41/2S, 1913-22 Columbus (Ohio) Swr., 41/2S, 1921 Columbus (Ohio) F. D., 4s, 1916 Columbus (Ohio) 4s, 1927 Columbus (Ohio) Swr., 4s, 1933 Columbus (Ohio) Wtr., 4s, 1945 Columbus (Ohio) 31/2S, 1932 Columbus (Ohio) Sch. Dis., 4s, 1926 Columbus (Ohio) Sch. Dis., Si/gS, 1923 Columbus (Ohio) 4s, 1922 Cuyahoga Co. (Ohio) 5s, 1913-20 Cuyahoga Co. (Ohio) Eef. 4s, 1913-26 (^yahoga Co. (Ohio) 4s, 1913-41 Cuyahoga Co. (Ohio) 41/2S, 7^-71/2 yrs Cuyahoga Co. (Ohio) 41/38, 1920 Cuyahoga Co. (Ohio) Rd. 41/2S, 1914-22 Cuyahoga Co. (Ohio) 4s, 1924-27 Cuyahoga Co. (Ohio) Ser. 1914-43 Dayton (Ohio) 5s, 1915 Dayton (Ohio) 4s, 1913-18 Dayton (Ohio) Wtr., 31/2S, 1913-15 Dayton (Ohio) Sch. Dis., 4s, 1920 Dayton (Ohio) 5s, 514 to 6 yrs Defiance (Ohio) 5s, 1914-15 Defiance (Ohio) 41/2S, 1913-16 Delphos (Ohio) Sch., 41/4S, 1917-45 Dover (Ohio) Sch., 5s, I61/4 yrs East Cleveland (Ohio) "Sch., 4s, 1932 East Liverpool (Ohio) Ref., 4s, 1940 East Palestine (Ohio) Sewer, 5s, 4 yrs Elyria (Ohio) Wtr. 4s, 1913-23 Elyria (Ohio) Wtr. 4s, 1924-28 Elyria (Ohio) Sch. 41/38, 1917-20 Elyria (Ohio) Sch. 4s, 1924-40 Elyria (Ohio) 4s, 1925-50 Fostoria (Ohio) 4s, 1925 Franklin Co. (Ohio) Def. & Bdg. 5s, 1913 Franklin Co. (Ohio) Fund 4s, 1914-19 Franklin Co. (Ohio) Bldg. 4s, 1914-25 Gallipolis (Ohio) Wtr. 5s, 1914 Gallipoli (Ohio) Red. 4s, 1920 Glendale (Ohio) Wtr. 41/2S, 1-4 yrs Glenville (now Cleveland) Sewer 41/2S, 1917-32 Grafton (Ohio) Rd. 5s, 1927-28 Hamilton (Ohio) 4s, 1940 Hamilton (Ohio) Gas 5s, 1914-18 Hamilton (Ohio) 41/38, 1919 Hamilton Co. (Ohio) 58, 1934 Hamilton Co. (Ohio) C. H. 4s, 1921-39 Hardin (Ohio) 58, 1915-18 •Quotation nearest March 1, 1913. No quotation on that date 1185 High Low Bid Asked __ *100 _- *3.90% basis — *3.90% basis __ *3.80% basis __ *103.62 3.80% basis _. _- _- *96i/2 __ *3.85% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis __ *100 3.80% basis 3.80% basis 3.80% basis *100 3.85% basis __ *3.85% basis __ *3.80% basis __ *3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis ♦102.53 _- 4% basis 4% basis _- *3.95% basis *105V4 — ._ *3.85%, basis 3.90% basis *100.10 — 4% 4% *3.90% *3.85%, *378% 4% 3.80% 3.80% 3.80%, 3.90%) 3.90% *3.90% *4% 3.90% 3.90% 3.70%? 3.70% *4y4% basis basis basis basis basis basis basis basis basis basis basis 100.431 basis ♦10314 basis basis basis basis OHIO (Continiiea). High Low Bid Asked Hardin (Ohio) 4s, 1915-22 __ __ •3.80% basis Harris (Ohio) Rd. 5s, 26%yrs __ __ *103.02 „ Kennedy Hghts. (Ohio) Sch. 4s, 1952 __ „ __ *104y2 Knox Co. (Ohio) 5s, Ser. 1 to 5 yrs __ __ *101.52 __ Lake Co. (Ohio) Rd. 41/2S, 12 yrs __ __ *100.80 __ Lake Co. (Ohio 4y2S, 12y6 __ __ *100.61 — Lake Co. (Ohio) 4s, 1921 __ __ *3.85% basis Lake Co. (Ohio) 4y33, 1923-29 „ __ *4.30% basis Lakewood (Ohio) 4y2S, 1921-39 — „ 4% basis Lakewood (Ohio) 5s, 3y2 to 6 yrs __ __ *100.80 „ Lakewood (Ohio) 5s, 5% to 13l^ yrs __ __ *101.53 _. Lakewood (Ohio) 5s, 22y2 yrs __ __ *107.40 __ Lakewood (Ohio) Sch. 4y2S, 1913 __ __ *4% basis Lakewood (Ohio) St. 5s, 1914-31 __ „ *4y2% basis Lakewood (Ohio) Sch. 4y2S, 1928-34 __ __ *3.90% basis Lima (Ohio) 5s, 1916 __ __ 3.90% basis Lima (Ohio )Swr. 4s, 1913-25 __ __ 3.90% basis Lima (Ohio) Ref. 3y2S, 1930 __ __ 3.90% basis Lockland (Ohio) Sch. 4s, 1952 __ __ __ *104^ Lorain (Ohio) Riv. Imp. 58, 1918-32 __ __ 4% basis Lorain (Ohio) 4y2S, 10 yrs __ __ *100.875 __ Louisville (Ohio) St. 5s, Ser. 3 to 6 yrs __ __ *100.403 __ Lucas Co. (Ohio) Ct. Hse. 4s, 1944 __ __ 3.80% basis Lucas Co. (Ohio) 5s, 1917 __ __ *4% basis Lucas Co. (Ohio) Rd. 4y2S, 1915-21 __ __ *3.80% basis Lyme Co. (Ohio) 5s, 9% yrs __ __ *101.81% basis Madison Co. (Ohio) 58, 1914-15 __ __ *4% basis Madisonville (Ohio) 5s, 1932 __ __ 3.80% basis Marietta (Ohio) 3y2S, 1931 __ __ 3.90% basis Marion (Ohio) Swr. 5s, 1914-23 __ __ 3.90% basis Martin's Ferry (Ohio) Sch. 5s, 1926-44 >_ __ 3.90% basis Matamoras (Ohio) St. 4s __ __ *100 Mercer Co. (Ohio) 5s, 1914-24 __ __ 3.90% basis Middletown (Ohio) Pk. 4s, 1930 __ — 3.90% basis Middletown (Ohio) St. 4y2S, 1-10 yrs __ __ *100.102 __ Norwood (Ohio) 5s, 1915 __ __ 3.85% basis Norwood (Ohio) 4y2S, 1925 __ „ 3.85% basis Norwood (Ohio) 4s, 1930 __ — 3.85% basis Montgomery Co. (Ohio) 5s, 2 yrs __ __ *100i4 __ Montgomery Co. (Ohio) 5s, 414 yrs __ — *101.13 — Monroeville (Ohio) St. 5s, 1920 — __ *4% basis Portsmouth (Ohio) 4s, 1913-24 __ __ 3.80% basis Portsmouth (Ohio) Sch. D. 3y2S, 1917-22 „ — 3.80% basis Navarre (Ohio) 4y2S, Ser __ __ *3.85% basis Newburg (now Cleveland) Sewer 4y2S, 1913— __ __ *4% basis Newburgh Hghts. (Ohio) Wtr. 4y2S, 1932 __ — *3.90% basis Niles (Ohio) Wtr. & -Elec. Lt. 5s, 16 to 17 yrs __ __ 105.69 to 106.03 Norwalk (Ohio) 5s, 9% yrs — __ *102.056 „ Oak Run (Ohio) Sch. 5y2S, 5% __ _. *103.536 — Oakley (Ohio) St. 5s, 1913-22 — — *3.85% basis Palestine (Ohio) Sch. 6s, 5% yrs __ — *104.904 __ Paulding Co. (Ohio) 5s, 4 yrs __ __ *101.08 __ Pemberville (Ohio) Sch. 5s, 914 - __ — *101 1/5 __ Pike (Ohio) Sch. 5y2S, Ser. 2-7 — — *100y2 — Piqua (Ohio) 'Sch. 4s, 1942-48 __ __ *3.80% basis Portage Co. (Ohio) 4y2S, 1914-27 „ — *3.85% basis Pleasant Ridge (Ohio) Sch. 4y2S, 1936-42 __ __ "S.SS^) basis ^Quotation nearest March 1, 1913. No quotation on that date. 1186 OHIO (Continued). Pultney (Ohio) Rd. 5s, Ser. 10 to 19 yrs Salem (Ohio) 43, 1925 Sandusky (Ohio) Wrf. 5s, 1914-26 Sandusky (Ohio) St. Imp. 4s, 1914-18 Sandusky (Ohio) 4s, 9% yrs Sandusky (Ohio) 4s, 1922 Sandusky (Ohio) 4s, 1917-24 Sandusky (Ohio) Sch. 4s, 1915-51 Steubenville (Ohio) 4s, 1924 Tiffin (Ohio) 4s, 1915 Shaker Heights (Ohio) Sewer & Wtr. 5s, 1914-22 Stark Co. (Ohio) Rd. 5s, 4 yrs Struthers (Ohio) Sch. 41/33, 1926-45 Sullivan (Ohio) Rd. 5s, 10 yrs Toledo (Ohio) 5s, 1913 Toledo (Ohio) 41/38, 1919 Toledo (Ohio) 41/2S, 1914 Toledo (Ohio) Bdge., 4l^s, 1928-38 Toledo (Ohio) 4s, 1926 Toledo (Ohio) Pk. 4s, 1942 Toledo (Ohio) Ref. 31/2S, 1930 Toledo (Ohio) Sch. D. 4s, 1923-29 Springfield (Ohio) Fire 5s, 1915-21 Springfield (Ohio) Bldg. 41/3S, 1913-21 Springfield (Ohio) 4s, 1921-25 Springfield (Ohio) 41/2S, 1913-14 Springfield (Ohio) 41/38, 1934 Troy (Ohio) St. 48, 1925-32 Tuscarawas (Ohio) 5s, 5% yrs Union Co. (Ohio) 5s, 1% yrs Urbana (Ohio) Sewer 4i/4s, 1928-29 Van Wert Co. (Ohio) Rd. 6s, 1913-19 Warren (Ohio) 4s, 8l^ yrs Warren (Ohio) 4s, 1932-33 Willoughby (Ohio) 41/38, 1932 Wooster (Ohio) 4i^s, 1932 Youngstown (Ohio) Pk. 58, 1914 Youngstown (Ohio) Fire 5s, 1913 Youngstown (Ohio) II/3 to 3l^ yrs Zanesville (Ohio) 4s, 1915 OKLAHOMA Oklahoma, Funding 4s, 1918-27 Allen (Okla.) 6s, 1937 Anadarko (Okla.) Elec. Lt. 51/3S, 1929 Canadian Co. (Okla.) Ct. H. 48, 1922-31 Ardmore (Okla.) 5s, 1922 Ardmore (Okla.) 58, 1937 Atoka Co. (Okla.) 5s, Serially Bartlesville (Okla.) 1913-22 Blackwell (Okla.) 6s, 1937 Bokchito (Okla.) 6s, 1937 Checotah (Okla.) Wtr. 6s, 1926 Clinton (Okla.) 6s, 1933 Clinton (Okla.) 6s, 1938 'Quotation nearest March 1, 1913. No quotation on that date. Wt 1187 High Low Bid Asked ♦103.069 __ *3.90% basis 3.80% basis 3.80% basis *100 - *100i/8 *3.80% basis *3.85% basis 3.90% basis 4% basis *4i/2% basis *101.81 _- *4.30% basis 101.64 __ __ *100i/8 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis 3.80% basis *4% basis •*3.80% basis *3.80% basis *101.51 __ *100.18 __ *3.85% basis 3.80% basis *100.40 „ *3.90% basis *4% basis *3.90% basis 3.80% basis 3.80% basis ^100.04 to 101.04 3.80% basis 993/4 100 __ *103.29 __ *104.17 98 4^8% basis __ *102.89 *4.70% basis *106%% basis *103.29 „ __ *106 *5.40% basis __ *108.18 OKLAHOMA (Continued). CoUinsville Wtr. & Sewer 6s, 1938 Dewey (Okla.) Sch. 6s, 1929 Durant (Okla.) Sewer &. Wtr. 6s, 1933 Enid (Okla.) Sewer 53, 1919-34 Enid (Okla.) 5s, 1937 Erick (Okla.) Sch. 6s, 1933 Enfaula (Okla.) 68, 1937 Francis (Okla.) Wtr. 6s, 1936 Frederick (Okla.) 6s, 1928 Garvin Co. (Okla.) Sch. 5s, 1928 Gaymon (Okla.) 6s, 1923-32 Guthrie (Okla.) 5s, 1933 Hastings (Okla.) 6s, 1937 Heavener (Okla.) 6s, 1*932 Hughes Co. (Okla.) Sch. 6s, 1932 Idabeir(Okla.) 6s, 1937 Lincoln Co. (Okla.) 6s, 1917-24 Love Co. (Okla.) 51/28, 1937 McAlester (Okla.) Sch. 5s, 1937 Mcintosh Co. (Okla.) Sch. 6s, 1932. Miami (Okla.) Wtr. & Lt. 53, 1920-35 Mounds (Okla.) 5s, 1929 Mounds (Okla.) 6s, 1933 Muskogee (Okla.) 41/28, 1925 Muskogee (Okla.) 5s, 1924 Muskogee (Okla.) Fdg. 5s, 1929 __ Muskogee (Okla.) 41/2S, 1929 Muskogee (Okla.) Sch. 5s, 1936 Muskogee (Okla.) 5s, 1937 Muskogee Co. (Okla.) Sch. 6s, 1929 Payne Co. (Okla.) Ref. 41/oS, 1920-29 Payne Co. (Okla.) Sch. 6s, 1924 Osage Co. (Okla.) Sch. 6s, 1932 Osage Co. (Okla.) Sch. 6s, 1932 Osage Co. (Okla.) 6s, 1938 Oklahoma City (Okla.) Sch. D. 6s, 1914 Oklahoma City (Okla.) 4s, 1933 Oklahoma Co. (Okla.) 41/28, 1924-33 ^..^ Oklahoma City (Okla.) 6s, 1915 Oklahoma City (Okla.) 5s, 1937 Oklahoma City (Okla.) Wtr. 5s, 1936 Oklahoma City (Okla.) Fdg. 5s, 1936 Oklahoma City (Okla.) Fire 53, 1934 Oklahoma City (Okla.) Swr. 41/2S, 1936 Oklahoma City (Okla.) 5s, 1935 Ponca City (Okla.) 58, 1932 Pond Creek (Okla.) 5s, 1931 Porum (Okla.) Wtr. & Elec. Lt. 68, 1937 Shawnee (Okla.) 5s, Serially Shawnee (Okla.) 6s, 1918 Sapulpa (Okla.) Sch. 5s, 1928 'Sapulpa (Okla.) Wtr. & Sewer 5s, 1933 Skiatook (Okla.) 6s, 1937 Stillwater (Okla.) Wtr. 5s, 1933 Strike Axe (Okla.) 6s, 1921-36 Tonkawa (Okla.) Wtr. 6s, 1937 Tulsa (Okla.) 5s, 12 to I41/2 yrs 'Quotation nearest March 1, 1913. No quotation on that date. 1188 High Low Bid Asked — *110.38 „ '107.72 -_ *109.22 *4%% basis — *102.89 -_ *106 __ *5%% basis __ *106i/2 __ *1133/8 __ *100 __ *5i/2% basis -_ *103l^ __ *103.29 *6% basis _- •514% basis __ *108.18 *6% basis __ *108.59 __ "4.80% basis -_ *5i/4% basis *5% basis __ *100 __ 109.23 414% basis 478% basis 4y8% basis ._ _. __ *98i/2 __ *4.80% basis __ *104.36 *5l^% basis 41/4% basis *5i/8% basis •51/8% basis •514% basis *4.90% basis 101 98.26 — 414% basis 101 4%% basis 478% basis 434% basis 4%% basis 41/0% basis I- '10478 *5% basis *5% basis __ '106 •4.80% basis __ "100 *5% basis -_ *98.60 __ *103.29 *5 %basis •514% basis *5i/2% basis •100 I OKLAHOMA (Continued). High Tulsa (Okla.) 5s, 1930 Tulsa (Okla.) Sch. 1932 Coatesville (Pa.) 4s, 1926-41 Tulsa (Okla.) 58, 1932 Tulsa (Okla.) 5s, 1931-36 Wagoner (Okla.) 5s, 1937 Willow (Okla.) 6s, 1932 Wellston (Okla.) Wtr. 68, 1936 Wellston (Okla.) 6s, 1936 OREGON Dallas City (Ore.) 5s, 1917-26 Dallas City (Ore.) Sewer 5s, 1932-37 Albany (Ore.) 5s, 1931 Butte Falls (Ore.) Wtr. 6s, 1932 Coos Bay (Ore.) Port 58, 1933-44 Glendale (Ore.) 6s Eugene (Ore.) 58, 1942 Portland (Ore.) C. H., 5s, 1922 Portland (Ore.) Wtr., 5s, 1923 Portland (Ore.) Bdge., 5s, 1925 Portland (Ore.) Bdge., 4s, 1934 Portland (Ore.) Wtr., 48, 1937 Portland (Ore.) S. D., 5s, 1914 Hermiston (Ore.) Sch., 5s, 10 to 20 yrs La Grande (Ore.) 6s, 1 to 10 yrs La Grande (Ore.) 6s, 1913-22 Medford (Ore.) 5s, 1921 Milwaukee (Ore.) 6s, 1921 Pendleton (Ore.) 6s, 1923 Pilot Rock (Ore.) Wtr., 6s, 1932 Port of Portland (Ore.) 5s, 1922 Port of Portland (Ore.) Dry Dk., 4s, 1934 St. Johns (Ore.) St., 6s, 1 to 10 yrs St. Johns (Ore.) 6s, 1922 Union Co. (Ore.) Sch., 6s, 1923-33 Low Bid Asked __ *101.12 *4.70% basis *4% basis __ *103.86 *4%% basis _- *100 __ *103.29 __ *106 __ *103.29 4.60% basis *4%% basis 4.70% basis *5.75% basis *4.90% basis *95 __ 104 4y2-.35% basis 4y2-.35% basis 4y2-.35% basis 4y2-.35% basis 94 9514 4i4-.35% basis *99 *100.802 — ♦514% basis __ *102ya __ *101 *5% basis __ *102.90 4y2-y4% basis 4y2-y4% basis ♦100.972 __ •514% basis _- *102 PENNSYLVANIA Pennsylvania Agr. College 5s, 1922 Allegheny (Pa.) 4s, 1913-19 Allegheny (Pa.) 4s, 1917-27 Allegheny (Pa.) St. Imp., 4s, 1937 Allegheny (Pa.) 3y2S, 1913-31 Allegheny Co. (Pa.) 4s, 1934 Allegheny Co. (Pa.) Rd., 4s, 1937 Allegheny Co. (Pa.) Rd., 4s, 1938 Allegheny (Pa.) Bdge., 4s, 1942 Allegheny Co. (Pa.) 3y2S, 1932 Allegheny Co. (Pa.) Rd., 4s, 1936 Allegheny Co. (Pa.) Rd., 48, 1936 Allegheny Co. (Pa.) 4s, 1941 Altoona (Pa.) 48, 1934 Altoona (Pa.) Ref., 4s,1936 Altoona (Pa.) Highw., 48, 1937 Altoona (Pa.) S. D. 48, 1913-35 Braddock (Pa.) 48, 1913-35 'Quotation nearest March 1, 1913. No quotation on that date. 1189 4% 4.10% 4.20% 4% 4% 4.10-.05% 4.10-.05% 4.10-.05% 4-3,95% 3.95% basis basis basis basis basis basis basis basis basis __ *98y, *4.10% basis _- *101 basis basis basis basis basis 4% 4% 4% 4.20% 4.30% PENNSYLVANIA (Continued). High Bridgeville (Pa.) Sch., 41/28, 1933 Canoasburg (Pa.) 4s, 12 yrs Chester (Pa.) SVgS, 1939 Chester (Pa.) 4s, 1937 Chester (Pa.) S. D., SVzS, 1931 Coatesville (Pa.) 4s, 1926-41 College Hill (Pa.) 41/38, 1919-42 East McKeesport (Pa.) Sch., 41/2S, 1934-41 Easton (Pa.) 31/38, 1938 Easton (Pa.) S. D., 4s, 1924 Erie (Pa.) Ref., 4s, 1914 Erie (Pa.) St., 4s, 1921 Edgewood (Pa.) 41/38, 1928-34 Exeter (Pa.) Sewer, 5s, 1913-17 Freedom (Pa.) 41/38, 1935-42 Harrisburg (Pa.) 4s, 1920 Harrisburg (Pa.) 48, 1921 Hazleton (Pa.) 4s, 1936 Homestead (Pa.) 5.40s, 1915 Houston (Pa.) 41/3S, 1930-40 Houston (Pa.) 41/38, 1938 Ingram (Pa.) St. & Sewer, 41/38, 1940-42 Johnstown (Pa.) 5s, 1921 Johnstown (Pa.) 41/38, 1923 Johnstown (Pa.) Bldg., 48, 1930 Knoxville (Pa.) St., 4iA8, 1936 Lancaster (Pa.) Wtr., 4s, 1913-20 Lancaster (Pa.) St., 48, 1938 Lancaster (Pa.) 4s, 1925 Lansdowne (Pa.) 4l^8, Ser. 1 to 30 yrs Ligonier (Pa.) 41/38, 1927-42 McDonald (Pa.) 41/38, 1922-2^ Midland (Pa.) 41/38, 1913-32 Monongahela (Pa.) 41/3S, 1937-38 New Castle (Pa.) 414s, 1927-33 Norwood (Pa.) Sch., 41/38, 1933-43 Old Forge (Pa.) 5s, 1938-43 Parnassus (Pa.) Sch., 41/38, 1933-43 Patton (Pa.) 41/38, 1931-31 Philadelphia (Pa.) 31/3S, 1919 Philadelphia (Pa.) 31/3S, 1930 Philadelphia (Pa.) 31/oS, 1931 Philadelphia (Pa.) 31/38, 1932 Philadelphia (Pa.) 31/3S, 1925 Philadelphia (Pa.) 31/3S, 1926 Philadelphia (Pa.) 31/38, 1937 Philadelphia (Pa.) 38, 1931__^ Philadelphia (Pa.) 38, 1930 Philadelphia (Pa.) 4s, 1937 Philadelphia (Pa.) 4s, Jan. 1938 Philadelphia (Pa.) 48, July 1938 Philadelphia (Pa.) 48, 1940 Philadelphia (Pa.) 4s, 1941 Philadelphia (Pa.) 4s, 1943 Philadelphia (Pa.) Wtr., 31/38, 1931 Philadelphia (Pa.) 31/3S, 1933 Philadelphia (Pa.) 31/38, 1934 'Quotation nearest March 1, 1913. No quotation on tliat date. 1190 Low Bid Asked __ *4.15% basis *100.55 -_ 4.05% basis 4.10% basis __ 4.10-4% basis *4% basis -_ *4.30% basis — *4l^% basis 4% basis 4% basis 4.10% basis 4.10 %basi3 __ *4i/8% basis __ *101i/i __ *4.30% basis 4% basis __ *97i/4 4.40% basis 4.10% basis *4% basis *104.73 — __ *4.10% basis 4.10% basis 4% basis 4.10% basis — ,*103.i4 3.90% basis 3.90% basis _- *99 *101.60 _- __ *4.30% basis *4i/8% basis __ *4.30% basis *4.15% basis — *4.10% basis -_ *4i/4% basis __ *4.35% basis __ *4.15% basis — *4.30% basis 951/0 ._ 95 943/4 „ 941/2 __ 94 94 .- 931/3 , 901/3 -_ 871/2 - __ 3.96-.94% basis __ 3.96-.94% basis __ 3.96-.94% basis __ 3.96-.94% basis -_ 101 10034 101 __ 4-3.95% basis __ 4-3.95% basis 4-3.95% basis PENNSYLVANIA (Continued). High Low Bid Asked Philadelphia (Pa.) S. D., 4s, 1923-42 __ __ 3.98% basis Philadelphia (Pa.) 31/2S, & 3s ^ __ __ *4.10% basis Philadelphia (Pa.) Sch., 4s, Ser. 1924 __ __ *3.95% basis Pittsburgh (Pa.) 41/4 s, 1913-40 __ __ 4.10-4% basis Pittsburgh (Pa.) 4s, 1925 „ __ 4.10-4% basis Pittsburgh (Pa.) 4s, 1913-27 __ __ 4.10-4% basis Pittsburgh (Pa.) 4s, 1914-39 __ __ 4.10-4% basis Pittsburgh (Pa.) 4s, 1913-36 __ __ 4.10-4% basis Pittsburgh (Pa.) 41/28, 1913-38 __ __ 4.10-4% basis Pittsburgh (Pa.) 414s, 1913-30 __ __ 4.05% basis Pittsburgh (Pa.) 4l^s, Ser. 1913-42 __ __ *4.05% basis Pittsburgh (Pa.) Sch., 4s, 1922-42 __ __ *4.10% basis Plymouth (Pa.) Sch., 58, 1934-36 _> __ *4i^% basis Reading (Pa.) 4s, Apr. 1913-28 __ __ 4-3.90% basis Reading (Pa.) 4s, Sep. 1913-28 __ __ 4-3.90% basis Reading (Pa.) 4s, 1918 __ — 4-3.90% basis Schylkill Co. (Pa.) 4s, 1916 __ __ 4% basis Schylkill Co. (Pa.) 3s, 1921 __ __ 4% basis Scranton (Pa.) 41/4S, 1914-41 __ __ 4.05% basis Scranton (Pa.) 4s, 1914-37 __ — 4.05% basis Scranton (Pa.) 4s, 1915-35 __ __ 4.05% basis Scranton (Pa.) 31/28, 1915 __ — 41/2% basis Scranton (Pa.) S. D., 4s, 1915-33 __ __ 4.10% basis Scranton (Pa.) S. D., 31/2S, 1914-32 __ __ 4.10% basis Turtle Creek (Pa.) 41/2S, 1941 __ __ *4.20% basis Uniontown (Pa.) Imp., 4s, 1928 __ __ 4.40% basis Washington Co. (Pa.) Rd., 41/2S, Ser. 1913-27— __ — *4.20% basis Waynesboro (Pa.) Sch., 41/2S, 1927-42 __ __ *4i/i% basis Williamsport (Pa.) 31/2S, 1929 __ __ 41/2% basis Wilkesbarre (Pa.) 31/2S, 1914-29 _. __ 4.10% basis Wilkesbarre (Pa.) 4s, 1914-35 _*— __ __ 4.10% basis Wilkesbarre (Pa.) 4s, 1931 __ __ — *100 Woodlawn (Pa.) Sch., 41/2S, 1941 >_ __ *4.30% basis RHODE ISLAND Rhode Island S. H., 31/2S, 1934 __ »_ 99 Rhode Island S. H., 3s, 1938 __ __ 89 Bristol (R. L) 31/2S, 1930 __ __ 90 Burrillville (R. L) 3i/.s, 1939 __ __ 90 Burrillville (R. L) 31/38, 1942 „ — — *90% Cranston (R. L) 4s, 1939 __ __ 98 East Prov. (R. I.) Fdg., 4s, 1947 — — 98 East Prov.(R. L) 41/38, 1917 — — — *100 East Prov (R. I.) 41/38, 1932 — — — *100 East Prov. (R. L) 4s, 1933 __ — — *95 East Prov. (R. L) 4s, 1948 __ — — *94 Jamestown (R. L) 41/38, 1931 __ >_ — *103.83 Johnstown (R. L) Sch., 48, 1915-33 _- ♦4.35 to 41/2% basis Johnstown (R. L) 4s, 1925-33 __ «_ ♦4.40%, basis Lincoln (R. L) 4s, 1928 -_ __ 97 Newport (R. L) 4s, 1927 __ __ 98 Newport (R. L) 48, 1948 >_ __ 99 Newport (R. L) Sch., 31/38, 1954 __ __ 88 Newport (R. L) 48, 1915-18 __ __ *4.15% basis Newport (R. L) 4s, 1918 __ — — *99% Pawtucket (R. L) Wtr., 4s, 1937 98 •Quotation nearest March 1, 1913. No quotation on that date. 1191 RHODE ISLAND (Continued). Pawtucket (R. I.) Si/jS, 1922 Pawtucket (R. I.) 48, 1944 Providence (R. I.) 48, 1921 Providence (R. I.) 4s, 1927 Providence (R. I.) Wtr., SVgS, 1916 Providence (R. I.) Sch., SVgS, 1929 Providence (R. I.) Swr., 3s, 1929 Providence (R. I.) SVgS, 1933 Tiverton (R. I.) 4s, 1924-29 Warren (R. I.) 4s, 1913-22 Westerly (R. I.) 4s, 1927 Westerly (R. I.) Wtr., 31/28, 1929 Woonsocket (R. I.) Fdg., 41/28, 1941 Woonsocket (R. I.) Fdg., 48, 1941 Woonsocket (R. I.) Wtr., 31/28, 1931 SOUTH CAROLINA South Carolina Blue, 41/28, 1928 South Carolina Ref., 41/2S, 1933 Anderson (So. Car.) 5s, 1933 Barnwell Co. (So. Car.) Sch., 6s, 1932 Barnwell (So. Car.) 5s, 1932-52-_-. Charleston (So. Car.) 5s, 1922 Charleston (So. Car.) 4i/s«, 1928 Charleston (Co. Car.) Swr., 4s, 1929 Charleston (So. Car.) 4a, 1937 Charleston (So. Car.) Ref., 4s, 1938 Cheran (S. C.) 6s, 1952 Columbia (So. Car.) 6s, 1921 Columbia (So. Car.) Ref., 58, 1941 Columbia (So. Car.) Wtr., 41/28, 1945 Darlington (So. Car.) 5s, 1932 Edgefield (So. Car.) 58, 1932-52 Greenville (So. Car.) 5s, 1940 Greenville (So. Car.) St., 58, 1942 Lawrence (So. Car.) 5s, 1942 Marion Co. (So. Car.) Sch., 5s, 1931-51 Orangeburg Co. (So. Car.) Sch., 51/2 s, 1932 Rock Hill (So. Car.) 58, 1951 Spartanburg (So. Car.) 41/2S, 1935 Sumter Co. (So. Car.) 41/2S, 1932 High Low Bid Asked 414% basis __ *96 98 98 97 93 87 - *92% ^4.30% basis 99 98 90 4.35% basis 4.30% basis 91 92 105 107 99 __ *105 ^5.20% basis __ *101 104 102 96 97 97 100 108 107 101 106 106 105 104 97 98 98 102 109 108 102 *105 »101 108 108 -_ *105i/a »4.65%) basis •51/4% basis 1021/2 1031/a 100 102 __ noiy. SOUTH DAKOTA Aberdeen (S. D.) Cs, 1915 Aberdeen (S. D.) 5s, 1913-21 Aberdeen (S. D.) Swr., 41/38, 1932 Aberdeen (S. D.) Swr., 41/2S, 1926 Fall River Co. (S. D.) 58, 1932 Faulk Co. (S. D.) 68, 1915 Marshall Co. (S. D.) 68, 1915 Garretson (S. D.) Elec. Lt., 5s, 1922 Lisseton (S. D.) Ss, 1926-31 Lyman Co. (S. D.) Sch., 6s, 1928 Madison (S. D.) Sewer, 6s, 1921-31 Mitchell (S. D.) 5s, 1924 ^Quotation nearest March 1, 1913. No quotatiou od that date. 1193 4%% 4%% 48/4% 43/4% 4.60% 4.60% •43/1% •51/4% basis basis basis basis ♦104.45 basis basis •100 basis basis •101 4%% basis SOUTH DAKOTA (Continued). High Pierre (S. D.) 3s, 1922 Redfield (S. D.) Sewer, 5s, 1933 Selby (S. D.) Wtr., Ss, 1924-29 Sioux Falls (S. D.) 5s, 1931 _' Watertown (S. D.) 5s, 1918-24 Yankton Co. (S. D.) 4s, 1919 TENNESSEE Tennessee Penitentiary, 4y^s, 1913 Tennessee Redemption 4l^s, 1913 Tennessee Settlement 3s, 1913 Blount Co. (Tenn.) 5s, 1921-51 Chattannoga (Tenn.) 5s, 1920 Chattanooga (Tenn.) Pub. Imp., 41/28, 1937— Chattanooga (Tenn.) Ref., 41/28, 1939 Chattanooga (Tenn.) Sr. & Fd., 41/28, 1941 Chattanooga (Tenn.) Park, 41/2S, 1942 Cock Co. (Tenn.) Rd. & Edge., 1919-39 Davidson Co. (Tenn.) 5s, 1913 Davidson Co. (Tenn.) Edge., 41/38, 1937— Davidson Co. (Tenn.) Trnpk., 4s, 1922 Dickson (Tenn.) Sch., 5s, 1943 Grainger Co. (Tenn.) 5s, 1940 Greene Co. (Tenn.) 5s, 1920 Hamblen Co. (Tenn.) 5s, 1939 Hamilton Co. (Tenn.) 41/38, 1941 Hamilton Co. (Tenn.) 41/38, 1942 Hamilton Co. (Tenn.) Rd., 5s, 1917-22 Jackson Co. (Tenn.) 5s, 1942 Knoxville (Tenn.) 6s, 1917 Knoxville (Tenn.) Imp., 5s, 1921 Knoxville (Tenn.) Ref., 58, 1940 Knoxville (Tenn.) Fd., 41/2*, 1937 Knoxville (Tenn.) Wtr., 41/28, 1949 Knoxville (Tenn.) 48, 1929 Lenoir (Tenn.) Wtr., 6s, 30 yrs London Co. (Tenn.) 53, 1942 Memphis (Tenn.) Comp., 6s, 1915 Memphis (Tenn.) Ref., 41/2S, 1926 Memphis (Tenn.) Ref., 41/38, 1939 Memphis (Tenn.) Str., 41/2S, 1946 Memphis (Tenn.) Pk., 41/3S, 1947 Memphis (Tenn.) 41/08, 1950 Memphis (Tenn.) Pk., 41/2S, 1959 Memphis (Tenn.) Wtr., 4s, 1933 Memphis (Tenn.) St., 6s, 1916 Memphis (Tenn.) 4s, 1929 Nashville (Tenn.) 'Sewer, 48, 1929 Nashville (Tenn.) Swr., 41/28, 1923 Nashville (Tenn.) Str., 41/38, 1935 Nashville (Tenn.) Swr., 41/3S, 1940 Nashville (Tenn.) Sch., 41/28, 1940 Nashville (Tenn.) Wtr., 4s, 1919 Nashville (Tenn.) T. C. R. R., 4s, 1924 Nashville (Tenn.) Swr., 4s, 1927 Nashville (Tenn.) Wtr., 4s, 1928 •Quotation nearest March 1, 1913. No quotation on that date. 1193 Low Bid Asked *88 II II •103.20 — *100 4.70% basis __ *4.70% basis 4.60% basis 991/2 lOOi/g 991/2 1001/3 981/2 991/3 4.70% basis — 48/4-1/2% basis — 48/4-1/2% basis — 48/4-1/2% basis 99 101 99 101 41/2% basis 4.40% basis 4.40% basis 4.40% basis __ *100 4.70% basis 4.65% basis 4.70% basis 4.40% basis __ 4.60-.40% basis _- *4i/2%, basis __ *103i/4 ~ 48^-1/2% basis __ 4%-i/3% basis — 43/4.1/2% basis __ 4.60-.40% basis -- 434.1/2% basis __ 4.60-.45% basis __ ^106.275 __ •1038/4 102 104 __ 4.60.1/0% basis __ 4.60-1/0%, basis __ 4.60-1/2% basis 99 101 __ 4.60-1/2% basis __ 4.60-1/2% basis __ 4.60-1/2% basis __ •41/2% basis — •41/2%) basis _. ^95 __ 4.60-1/2% basis __ 4.60-1/2% basis __ 4.60-1/2% basis __ 4.60-1/2% basis __ 4.60-1/3% basis __ 4.60-1/3% basis _- 4.60-1/2% basis >- 4.60-1/3% basis TENNESSEE (Continued). High Putnam Co. (Tenn.) 41/28, 1939 Putnam Co. (Tenn.) Rd., 41/28, 1941 Robertson Co. (Tenn.) 4s, 1941 Shelby Co. (Tenn.) Sch., 41/28, 1941 Shelby Co. (T^nn.) C. H., 4s, 1955 Sumner Co. (Tenn.) 4s, 1917-42 Low Bid Asked 99 100 99 100 4.40% basis 4.40% basis 4.40% basis - 4%-.60% basis TEXAS Amarillo (Tex.) Sewer & Rd., 5s, 1951 Austin (Tex.) 6s, 1913-42 Austin (Tex.) 5s, 1932 Austin (Tex.) Ref., 4-5s, 1931 Austin (Tex.) St., 5s, 1913-42 Austin (Tex.) 5s, 1930-42 Austin (Tex.) Sewer, 5s, 1933-42 Austin (Tex.) 5s, 1921-52 \ Austin (Tex.) 58, 1924-32-52 Austin (Eex.) 5s,-4s, 1931 Beaumont (Tex.) 5s, 1952 Beaumont (Tex.) 48, 1942 Beeville (Tex.) Sewer, 5s, 1920-30 Bosque Co. (Tex.) 58, 1952 Bryan (Tex.) 4s, 1929-49 Bryan (Tex.) 5s, 1951 Calhoun Co. (Tex.) Rd. Dis., No. 2, 5s, 40 yra. Calhoun Co. (Tex.) 5s, 1922-52 Calvert (Tex.) Sewer, 5s, 1953 Cameron Co. (Tex.) 5s, 1922-38 Cleburne (Tex.) Wtr., 5s, 1952 Corpus Christi (Tex.) 5s, 1922-52 Corpus Christi (Tex.) 41/28 Corpus Christi (Tex.) Sewer, 5s, 1920 Corpus Christi (Tex.) Sch., 41/3S, 1921-22 Corpus Christi (Tex.) Wtr., 4s, 1919-26 Corpus Christi (Tex.) Sh. & Sr., 41/2S, 1916-45 Corpus Christi (Tex.) 414s, 1950 Corpus Christi (Tex.) Sch., 41/2S, 1913-52 Dallas (Tex.) Fd., 6s, 1917 Dallas (Tex.) Wtr., 5s, 1917 Dallas (Tex.) 5s, 1931 Dallas (Tex.) 5s, 1928 Dallas (Tex.) Wtr., 4s, 1940 Dallas (Tex.) Wtr., 4s, 1913-49 Dallas (Tex.) Sch., 5s, 1913-51 Dallas Co. (Tex.) 41/2S, 1951 Dallas Co. (Tex.) 41/2S, 1921-31 Dallas Co. (Tex.) 41/38, 1951 El Paso (Tex.) Wtr. Purch.. 1950 El Paso (Tex.) Fund., 5s, 1951 El Paso (Tex. 1932-52 El Paso (Tex.) Wtr., Swr. & Lt., 5s, 1932-52 Fort Bend Co. (Tex.) Rd., 58, 10 to 40 yrs Fort Worth (Tex.) 6s, 1922 Fort Worth (Tex.) Ref., 5s, 1920 Fort Worth (Tex.) 58, 1951 Fort Worth (Tex.) Str., 41/2S, 1948 *QuotatiOD nearest March 1, 1913. No quotation on that date. 1194 __ "loa.os __ 4.85-.70% basis __ 4.85-.70% basis 951/2 98 — *4.70% basis __ *4.70% basis __ *4.70% basis __ *4.70% basis __ *4.70% basis *98 II 1031/4 103% 94 96V« __ *101.56 __ *103.06 -_ *89 *4%% basis __ *100 *5% basis *5% basis __ *5.20% basis 4.70% basis __ *102.28 __ *4.40% basis „ *103i4 __ *100 __ *4.35% basis __ *4%% basis __ *99 __ *4.38% basis __ 4%-.40% basis ~ 43^-l/4% basis — 43/4-14% basis ~ 43^-l^% basis 961/2 981/3 93 95 __ 4i/2-.40% basis 100 1011/3 __ MOI1/3 __ *100 100 1021/3 102 104 __ *103.85 -_ ♦103.85 *100.08 „ 1041/2 107 99 101 103 105 98 100 TEXAS (Continued). Fort Worth (Tex.) Sch., 4i/oS, 1948 Fort Worth (Tex.) Sch., 41/2S, 1949 , Fort Worth (Tex.) Ref., 4s, 1941 Fort Worth (Tex.) 5s, 1921 Frio Co. (Tex.) Rd., 5s, 40 yrs Harris Co. (Tex.) 5s, Serially Harris Co. (Tex.) 5s, 1939-39 Hidalgo Co. (Tex.) 5s, 1948 Galveston (Tex.) 5s, 1915 Galveston (Tex. Wtr., 5s, 1928 Galveston (Tex.) 5s, 1921 Galveston (Tex.) 5s, 1923 Galveston (Tex.) 5s, 1927 Galveston (Tex.) 5s, 1944 Galveston (Tex.) 41/33, 1948 Galveston (Tex.) 41/28, 1949 Galveston Co. (Tex.) 5s, 1951 Harris Co. (Tex.) 4s, 1947 Houston (Tex.) Comp., 5s, 1918 Houston (Tex.) Swr., 5s, 1939 Houston (Tex.) Ref., 5s, 1941 Houston (Tex.) 4i/oS, 1938 Houston (Tex.) 41/2S, 1931-41 Houston (Tex.) 43^3, 1913-52 Humboldt (Tex.) 41/2S, 1931 Johnson (Tex.) Wtr., 5s, 1940 Liberty Co. (Tex.) Rd., 5s, Serially Liberty Co. (Tex.) Rd., 5s, 1921-51 Longview (Tex.) Sewer, 5s, 1932-52 Longview (Tex.) Sch., 5s, 1932-52 Medina Co. (Tex.) Rd., 5s, 1917-52 New Braunfels (Tex.) Wtr., 41/2S, 1917-52 Orange Co. (Tex.) Rd., 5s, 1932-52 Port Arthur (T,ex.) 53, 1952 Reagan Co. (Tex.) 4s, 1950 Rockwall Co. Sch., 5s, 1929-49 San Angelo (Tex.) 5s, 1930-50 San Antonio (Tex.) 6s, 1917 San Antonio (Tex.) 5s, 1917 San Antonio (Tex.) 41/2S, 1920 San Benito (Tex.) St. & Swr., 6s, 1927-52___ Shonian (Tex.) 41/2S, 1917 Sweetwater (Tex.) 5s, 1932-52 Tarrant Co. (Tex.) 5s, 1952 Victoria (Tex.) Rd., 5s, 1917-52 Waco (Tex.) 5s, 1920 Waco (Tex.) 5s, 1934 Waco (Tex.) Swr., 5s, 1937 Waco (Tex.) 4s, 1931 Waco (Tex.) Wtr., 5s, 1942 Washington Co. (Tex.) 5s, Serially Yoakum (Tex.) Sewer, 5s, 1932-52 High Low 971/2 Bid Asked 95 98 100 91 921/3 __ *102.52 *100 __ *100 __ *100 __ *100 95 98 95 98 95 98 95 98 95 98 95 100 91 95 921/2 951/3 __ 4.90-.70% basis 95 96 101 1021/3 99 102 IO6I/3 100 __ ■'*101i/3 4.55% basis ._ *4.90% basis __ *102 __ *100 ._ *4y8% hasis — *103.20 __ *103.20 *4% to 5% basis __ *95.58 __ *102i/3 *4%% basis — *92 __ *102.87 __ *103i/3 _ 4.70-1/2% basis - 4.70-1/2% basis _ 4.70-1/2% basis .- *5i/4% basis __ *99.15 .- *4%% basis 4.55% basis *434% basis 100 101 100 101 -_ 101 90 93 1021/2 106 *5.15% basis __ *103.20 UTAH Utah State, 4s, 1916. Utah Ref., 31/38, 1918. "Quotation nearest March 1, 1913. No Quotation on that date. 1195 4iA% basis 414% basil UTAH (Continued). Utah Ref., 314s, 1920 Green River (Utah) Irr., 68, 11 to 20 yrs Logan (Utah) 5s, 1933 Box Elder Co, (Utah) 41/33, 1932 Ogden (Utah) 5s, 1913 Ogden (Utah) Wtr., 5s, 1914-15 Ogden (Utah) Wtr., 41/2S, 1929 Ogden (Utah) Ref., 41/28, 1932 Ogden (Utah) Ref., 4s, 1911 Ogden (Utah) S. D., 4s, 1922 Ogden (Utah) Seh., 41/3S, 10 to 20 yrs Ogden (Utah) 41/2S, 1933 Salt Lake City (Utah) 5s, 1914 Salt Lake City (Utah) Ref., 5s, 1924 Salt Lake City (Utah) Ref., 4s, 1921 Salt Lake City (Utah) Wtr., 4s, 1920 Salt Lake City (Utah) S. & W., 4s, 1925 Salt Lake City (Utah) S. D., 4s, 1930 Salt Lake City (Utah) S. D., 41/2S, 1932 Salt Lake Co. (Utah) 41/2S, 1926 Sevier Co. (Utah) Sch., 5s, 1922-32 High Low Bid Asked 414% basis " *102i/2 -_ 100 4.60% basis 4.60% basis 4.60% basis 4.60% basis 4.60% basis 4.60% basis __ ♦99 4.60% basis 4.60% basis 4.60% basis 4.60% basis 4.60% basis 4.60% basis 4.60% basis 4.55% basis __ *102.18 VERMONT Barre (Vt.) Wtr., 4s, 1914 Barre (Vt.) 31/2S, 1922 Bennington (Vt.) 4s, 1917 Brattleboro (Vt.) 4s, 1918 Burlington (Vt.) 4s, 1919 Middlebury (Vt.) 4s, 1941 Montpelier (Vt.) 4s, 1919 Rutland (Vt.) 4s, 1924 Rutland (Vt.) 4s, 1937 VIRGINIA Virginia, Deferred 6% Ctfs., 1871 Virginia, Brown Bros., 6% Ctfs 58 Virginia, Riddleberger, 5s, 1932 Virginia, Fund. Debt, 3s, 1991 Alexandria (Va.) 4s, 1938 Chase City (Va.) Wtr., 5s, 1942 Chatham (Va.) Wtr. Swr. & Lt., 51/38, 1927-42 Cheyenne (Wis.) 5s, 1931 Colonial Beach (Va.) Wtr. & Swr., 6s, 1937— Danville (Va.) Ref., 4s, 1931 Danville (Va.) 5s, 1910 Danville (Va.) 41/2S, 1942 Hampton (Va.) 58, 1949 Lee Co. (Va.) 5s, 1916-41 Lunenburg Co. (Va.) Rd., 6s, 20 yrs Lynchburg (Va.) Perm. Imp., 5s, 1926 Lynchburg (Va.) Ref., 41/28, 1927 Lynchburg (Va.) Pub. Imp., 41/38, 1939 Lynchburg (Va.) Ref., 43, 1934 Lynchburg (Va.) 4s, 1935 Lynchburg (Va.) 4s, 1936 ^Quotation nearest March 1, 1913. No quotation on that date. 1196 58 99 95 99 99 99 99 99 99 47 100 - 43/4 85 851/2 848/8 843/4 __ *92.46 ._ *101.26 __ *105.11 4.60% basis __ *106.62 4.60% basis __ *101.60 __ *100i/o __ *106.6i 4.70% basis *108.60 — 102 98 -.60% basis 911/0 .- - " *94i/2 - •941/2 VIRGINIA (Continued). Newport News (Va.) 41/28, 1948 Newport News (Va.) St., 4s, 1941 Newport News (Va.) 41/38, 1918-28 Newport News (Va.) 41/38, 1943 Newport News (Va.) 41/38, 1953 Norfolk (Va.) Renw., 6s, 1914 Norfolk (Va.) Renw., 6s, 1923 Norfolk (Va.) Imp., 41/38, 1942 Norfolk (Va.) Renw., 41/3S, 1941 Norfolk (Va.) Imp., 41/3S, 1940 Norfolk (Va.) 4s, 1963 Norfolk (Va.) Wtr., 4s, 1934 Norfolk (Va.) Imp., 4s, 1936 Norfolk (Va.) 5s, 1915 Norfolk (Va.) 5s, 1924 Norfolk (Va.) 4s, 1929 Norton (Va.) Sewer 5s, 1940 Portsmouth (Va.) 41/38, 1940 Portsmouth (Va.) Imp., 41/38, 1942 Richmond (Va.) 5s, 1920-22 Richmond (Va.) 4s, 1920-30 Richmond (Va.) 4s, 1938-43 Richmond (Va.) 4s, 1926 Richmond (Va.) 48, 1938 Richmond (Va.) 4s, 1941 Richmond (Va.) 4s, 1942 Richmond (Va.) 4s, 1943 Roanoke (Va.) Ref., 41/3S, 1936 Roanoke (Va.) St., 41/38, 1940 Roanoke (Va.) Imp., 4s, 1936 Tazewell Co. (Va.) 5s, 1923-46 Smyth Co. (Va.) Rd., 5s, 30 yrs Suffolk (Va.) 41/2S, 1936 Suffolk (Va.) 5s, 1942 WASHINGTON Washington 7s, 5 to 10 yrs Washington 6s, 10 yrs Washington Sch., 38, 5 to 15 yrs Aberdeen (Wash.) 51/3S, 1922-31 Bellingham (Wash.) 5s, 1926 Clallam Co. (Wash.) 41/38, 1921 Everett (Wash.) 5s, 1931 Everett (Wash.) 7s, 1 to 10 yrs Ferndale (Wash.) Wtr., 51/38, 1926-32 Franklin Co. (Wash.) 58, 1932 Kennewich (Wash.) Sewer, 51/3S, 1921-31 King Co. (Wash.) 5s, 1928 King Co. (Wash.) 41/38, 1931 Lewis Co. (Wash.) 5s, 1923-32 Mansfield (Wash.) Wtr., 6s, 1922-32 North Yakima (Wash.) 6s, 10 yrs Olympia (Wash.) 3%s, 1926 Pasco (Wash.) 7s, 1 to 10 yrs Pend Orielle Co. (Wash.) 41/3S, 1922-32 Pierce Co. (Wash.) Ref., 5s, 1925 Pierce Co. (Wash.) Ref., 4s, 1926 ♦Quotation nearest March 1, 1913. No quotation on that date. 1197 High Low Bid Asked 97 100 93 96I/3 _- *101i4 - *101i/3 __ *100 101 100 98 98 90 90 90 101 100 100 100 92 92 92 -_ *100i/3 - *103i/3 - *94i/8 __ *100 41/3% basis 100 41/0% basis 96 97 97 97 97 97 97 97 100 100 /2 -- 96 96 96 96 96 96 98 98 921/3 4.70% basis __ *100.05 __ *98 ^4.70% basis *102 to 103 - *100i/3 __ *95 4%%ba8ia 4.60% basis 4.80% basis 4^8% basis *103.837 — __ *10O __ *104.30 __ *104i/3 41/3% basis 41/2% basis 4.60% basis __ •103.66 __ *100 4%% basis *6i/8% basis *4.40% basis 4.55% basis 4.55% basii WASHINGTON (Continued). Seattle (Wash.) 5s, 1913-20 Seattle (Wash.) Swr., 41/28, 1927 Seattle (Wash.) Wtr., 41/28, 1931 Seattle (Wash.) Pk., 41/oS, 1931 Seattle (Wash.) St., 41/2S, 1932 Seattle (Wash.) 4s, 1929 Seattle (Wash.) Lib., 4s, 1922 Seattle (Wash.) S. D., No. 1, 41/2S, 1924 Seattle (Wash.) S. D., No. 1, 41/2S, 1931 Seattle (Wash.) Sch., 41/2S, 1918 Seattle (Wash.) 41/2S, 1932 Seattle (Wash.) Port, 41/2S, 1945 Seattle (Wash.) Port, 41/2S, 1926-48 Seattle (Wash.) Port, 41/2S, 1948-51 Skagit Co. (Wash.) 41/2S, 1921-31 Snohomish Co. (Wash.) 5s, 1931 Spokane (Wash.) Fd., 51/2S, 1918 Spokane (Wash.) Pk., 5s, 1927 Spokane (Wash.) Edge., 41/2S, 1931 Spokane (Wash.) Wtr., 41/28, 1935 Spokane (Wash.) Pk., 41/2S, 1962 Spokane (Wash.) Wtr., 4s, 1925 Spokane (Wash.) S. D., No. 81 41/2S, 1929 Spokane (Wash.) S. D. No. 81 41/2S, 1931 Spokane (Wash.) S. D. No. 81 4s, 1922 Spokane Co. (Wash.) 4s, 1921 Spokane (Wash.) 6s, 10 yrs Spokane (Wash.) Wtr. 5s, 1910-31 Sprague (Wash.) Wtr. & Lt. 51/2S, 1932 Sumas (Wash.) 7s, 1914-23 Stevens Co. (Wash.) 41/oS, 1929 Tacoma (Wash.) 41/2S Tacoma (Wash.) 73, 1914-18 Tacoma (Wash.) Wtr. 41/28, 1930-32 Tacoma (Wash.) 41/2S, 1932 Tacoma (Wash.) Wtr. 5s, 1933 Tacoma (Wash.) 5s, 1920 Tacoma (Wash.) Lt. & Pr. 41/2S, 1929 Tacoma (Wash.) Ref. 41/2S, 1931 L Tacoma (Wash.) S. D. No. 10, 41/38, 1920 Whatcom Co. (Wash.) 41/2S, 1922 WEST VIRGINIA Oiarleston (W. Va.) 41/2S, 1941 Clarksburg (W. Va.) S. D. 5s, 1941 Fairmont (W. Va.) Sch. 5s, 1927-42 Grafton (W. Va.) Wtr. 5s, 1934-45 Hancock (W. Va.) Grt. Rd. Dis. 5s, 1946 Hancock Co. (W. Va.) Rd. 5s, 20 to 34 yrs___ Kenova (W. Va.) 5s, 1939 Martensburg (W. Va.) 5s, 1943 McDowell Co. (W. Va.) Sch. 5s, 1933-43 Wheeling (W. Va.) 6s, 1924 Wheeling (W. Va.) City 5s, 1919 Wheeling (W. Va.) Edge. 41/2S, 1924 Wheeling (W. Va.) Ref. 4s, 1936 Union (W. Va.) 5s, 1923-34 'Quotation nearest March 1, 1913. No quotAtlon on that date. 1198 High Low Bid Asked 4.55% basis 4.55% basis 4.55% basis 4.55% basis 4.55% basis 4.55% basis 4.55% basis 4.55% basis 4.55% basis __ *99.83 ._ *100V4 *4.70% *97.33 to 4.70% 4%% 4y8% 4.55%j 4.55% 4.55% 4.55% 4.55% 4.55% 4.55% 4%% *4%% *5i/4% *6%% 100 *4.40% *6i/8% *4.40% *4i/2% 41/2% 41/2% 41/2% 41/2% 4.70%> basis 97.41 *100.90 basis basis basis basis basis basis basis basis basis basis basis *100 basis basis basis basis basis basis basis *101% basis basis basis basis basis ._ 4.60-1/2% basis __ 103.80 *4i/2% basis _- *4.60% basis -_ 103 -_ *100 __ *4%%, basis 4.60% basis __ *4.70% basis 103 101 100 98 101 — *4.70% basis I WISCONSIN Appleton (Wis.) 41/28, 1914-32 __ __ 4.30% basis Bayfield Co. (Wis.) 5s, 1918 — __ 4.35% basis Eagle River (Wis.) 5s, 1916-18 __ — *5% basis Green Bay (Wis.) 5s, 1914-17 — — 4.30% basis Green Bay (Wis.) Ref. 4s, 1913-20 __ __ 4.30% basis Junean Co. (Wis.) 6s, Ser. 1917-31 __ __ *5l^% basis Kenosha (Wis.) SVaS, 1919 „ — 4^4% basis La Crosse (Wis.) 5s, 1915 „ _. 4l^% basis La Crosse (Wis.) Wtr. 41/28, 1932 — — 4.30% basis La Crosse (Wis.) Wtr. 4s, 1931 __ __ 97 98 La Crosse (Wis.) Ref. 31/38, 1919 __ — 4.30% basis Langlade Co. (Wis.) 4s, 1914-23 __ „ 4.30% basis Madison (Wis.) 4s, 1925 „ __ 4l^% basis Marshfield (Wis.) 41/3S, 1922-32 __ __ 4.35% basis Milwaukee (Wis.) Lib. & Mun. 5s, 1917 — — 4.15% basis Milwaukee (Wis.) Wtr. 41/2S, 1932 — — 4.20% basis Milwaukee (Wis.) Viad. 4s, 1926 — __ 4.15% basis Milwaukee (Wis.) 31/38, 1921 — — 4.15% basis Milwaukee Co. (Wis.) 4s, 1925 __ — 4.15% basis Milwaukee Co. (Wis.) St. 4s, 1927 — — — *97% Monticello (Wis.) Wtr. 53, 1922-31 __ „ *4.75% basis New London (Wis.) 41/2S, 1917-27 — __ *4i/2% basis Oakfield (Wis.) 4s, 1914-32 __ __ *4.40% basis Owen (Wis.) Sewer 6s, 1917-21 __ — *5% basis Racine (Wis.) Ref. 41/2S, 1930 „ — 4l^% basis Racine (Wis.) Sch. 4s, 1923 >_ — 4i/4% basis Racine (Wis.) Sch. 31/2S, 1919 __ — 4.30% basis Racine Co. (Wis.) 4s, 1923 __ — 4.15% basis Racine Co. (Wis.) 41/3S, 1913-26 — — *4i4% basis Racine Co. (Wis.) 41/38, 1913-27 — __ *4.30% basis Racine Co. (Wis.) 41/38, 1924-27 — — *4.20% basis Rhinelander (Wis.) 1913-19 __ — 4%% basis Richland Center (Wis.) Elec. Lt. 4s, 1914-24__ __ __ *4.30% basis So. Milwaukee (Wis.) 6s, 1913 __ — 4.40% basis Stoughton (Wis.) Sch. 5s, 1916 — — — *102.10 Wausan (Wis.) 4s, 1913-25 __ — 4.35% basis Uinta Co. (Wis.) 41/3S, 1913-18 __ — 4.70% basis West AUis (Wis.) Sch. 6s -_ — *4.40% basis WYOMING GreybuU (Wyo.) Wtr. 6s, 1926-41 Guernsey (Wyo.) Wtr. 6s, 1925-40 Riverton (Wyo.) Wtr. 6s, 1925-40 Worland (Wyo.) Wtr. 6s, 1925-40 101 1011/2 101 101 FOREIGN COUNTRIES, CITIES, ETC. Amsterdam (Holland) 4s of 1900-01 __ __ 100 101 Amsterdam (Holland) 48 of 1904 __ __ 100 101 Argentine Republic Interm. 5s of 1909 „ __ 98 991/3 Augsburg (Ger.) 4s __ — 96 97iA Austrian Government, Perpet. 4s __ __ 107 108 Austrian Government Treas. 41/2S, 1914-15 __ „ 971/2 98 Baden (Grd. Duchy) 48, 1909 __ — 99 100 Bavaria (Ger.) 4s __ — 981/3 99% Berlin (Ger.) 31/2S __ — 89l^ 901/3 Brazil (U. S. of) 5s of 1903 — — 99 101 Chinese Government 5s — 100 101 ^Quotation nearest March 1, 1913. No quotation on that date. 1199 FOREIGN COUNTRIES, CITIES, ETC. (Continuea). High Low Bid Asked Chinese Government Hukuang Ry. 5s, 1951 — __ __ __ 88 Cologne (Ger.) 4s „ __ 99 100 Copenhagen (Denmark) 4s of 1901 — — 96 971/2 Copenhagen (Denmark) SVgS __ — 881/2 891/2 Cuba (Republic of) Extern 5s, 1944 lOli/g __ Cuba (Republic of) Intern. 5s, 1913 „ __ 96 97 Cuba (Republic of) Extern. 41/2S, 1949 — __ __ 97 Dominican Republic Cus. Adm. 5s, 1958 __ __ 100l^ France (Republic of) Perpet. 3s __ „ 88% 89% Frankfort (Ger.) 31/28 of 1901 __ __ 89 90iA Galisco (Mex.) 6s 1918-28 __ __ 95 100 Galisco (Mex.) 6s, 1921-30 __ __ 95 100 Galisco (Mex.) Sil. 6s, 1933 __ __ __ 45 German Government 31/2S __ »_ 86 87 German Government Perpet. 31/2S __ __ 86 87 German Government Perpet. 3s __ __ 75% 76% German Government New 4s 98 100 Great Britain Cons. 21/2S, op. 1923 „ __ 731/2 74% Hamburg (Ger.) 4s __ __ 981/2 98% Hamburg (Ger.) 3s of 1902 __ __ 7778 79 Havana (Cuba) 1st 6s, 1939 — — 106 108 Havana (Cuba) 2d 6s __ __ 103 105 Hawaii (Terr, of) Imp. 41/2S, 1921 __ __ 10014 __ Hawaii (Terr, of) Imp. 4%s, 1920 __ __ IOO1/4 »_ Hawaii (Terr, of) Imp., 4s, 1941 __ _. 1021/9 — Hawaii (Terr, of) Imp. 48, 1942 __ — 1021/3 — Hawaii (Terr, of) Imp. 31/2S, 1921 __ __ 95% „ Italian Government Perpet. 31/2S __ __ 97 98 Japanese Government 41/2S, 1925 __ 87% 89 Japanese Government Second Series 1925 __ __ 86% 871/3 Japanese Government 4s, 1931 __ __ 80% 8O1/3 Japanese Government 41/2S, 1925 8778 89 Japanese Government 2d 41/2S, 1925 __ __ 86% 871/2 Japanese Government 4s, 1931 80% 8O1/2 Mexico (U. 'S. of) Ref. 5s, 1944 __ __ __ 96% Mexico (U. S. of) Cons. 5s of 1894 __ __ 40 45 Mexico (U. S. of) 4s, 1954 _. __ __ 84 Mexico (U. S. of) Internal 3s __ __ 25 35 Munich (Switz.) 4s __ __ 97% 981/2 Philippine Islands Ld. Pur. 4s, 1934 >_ __ 1021/3 103% Philippine Islands Wtr. & Imp. 4s, 1935 _. __ 101% 103 Philippine Islands Man. R. R. So. L. 4s, 1939 — __ — 86 Philippine Islands Phil. Ry. 4s, 1937 — __ — 80% Porto Rico 4s, 1914-33 __ __ 3.80% basis Porto Rico, 4s, 1937 _. _. 103% __ Prussian Government Perpetual 38 75% Prussian (Ger.) 3s, 1902 „ „ 76 77 Prussian (Ger.) New 4s __ _. 98 991/3 Russian Government 4s of 1903 __ __ 891/2 91 Sao Paulo (Brazil) Treas. 5s, 1919 __ __ 961/3 97 Saxony (Ger.) 3s __ __ 77% 79 Stockholm (Switz.) 4s, 1941 __ __ 98 99 Swedish Government 4-31/2S, 1920 __ __ 85 88 Tokyo (Jap.) 5s of 1912 __ __ 86 Vera Cruz. (Mex.) 5s, 1930 __ __ 80 90 Vienna (Aus.) 4s _» __ 85 87 Wladikawkas (Russia) 4s, 1957 — __ 84 87 *Quotatlon nearest March 1, 1913. No quotation on that date. 1200 Treasury Decisions, etc. The following Treasury Decisions, Court De- cisions and other Income and Excess Profits Tax data promulgated under the Act of September 8th, 1916, as amended, and the Act of October 3rd, 1917, have been issued since the publication of the Stand- ard Manual of Income Tax for 1917, and although some of these Decisions have no direct bearing on the Revenue Bill of 1918, they are published for the guidance and benefit of those who may be required to file amended returns for the year 1917 and also for information where the subject matter pertains to the Revenue Act of 1918. 1201 (T. D. 2649.) Returns made by Dealers in Merchandise or Securities on the Basis of Inventories taken at "Cost or Market Value, which is Lower" will, Pending a Decision as to the Legality of this Basis, be Accepted Subject to Amendment. "A Dealer" Defined. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, January 30, 1918. To Collectors of Internal Revenue: T. D. 2609, issued under date of December 19, 1917, author- izes dealers in merchandise and dealers in securities to make their income-tax and excess -profits tax returns upon the basis of inventories taken "at cost or at market price, whichever is lower." The legality of this authorization having been questioned, the matter was referred to the Attorney General, who advises that the general principle at issue is involved in cases pending in the Supreme Court of the United States and that an early decision may be reasonably expected. Pending this deci- sion returns macie upon the basis of T. D. 2609 will be tenta- tively accepted. If the ruling of the Attorney General should be adverse to the principle enunciated in the Treasury decision referred to, dealers in merchandise or in securities who shall have made returns on the basis of inventories taken at a value other than cost will be required to make amended returns upon the basis of inventories taken at cost. In making their returns in the first instance, for the taxable year 1917, dealers in mer- chandise or in securities will be required to indorse upon or attach to such returns a statement specifying the basis upon which the inventories were taken, whether at cost or market price. For the purposes of T. D. 2609 and this decision, a dealer in securities is a merchant of securities, whether an individual, partnership, or corporation, with an established place of busi- ness and whose principal business is the purchase of securities and their resale to customers, that is, one who, as a merchant, buy* securities and sells them to customers with a Adew to the gains and profits that may be derived therefrom. Taxpayers who buy and sell or hold securities for investment or specu- lation, and not in the course of an established business, officers of corporations or members of partnerships who in their individual capacities buy and sell securities are not "dealers in securities" within the meaning and purpose of T. D. 2609 or this decision, and in all such latter cases inventories, if taken, must be taken at cost and the gain or loss will be determined and taken into account as the securities are sold and the transactions closed. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved : W. G. McADOO, Secretary of the Treasury. 1203 (T. D. 2652.) Interest on Bank Deposits Paid to Non-Resident Alien Indi- viduals Is Subject to Withholding Provisions of Act of October 3, 1917. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, February 6, 1918. To Collectors of Internal Revenue and Others Concerned: Interest received from deposits in banks located within the United States constitutes income received from sources within the United States and is subject to the withholding provisions of the Act of September 8, 1916, as amended by the Act of October 3, 1917, as to non-resident alien individuals. Banks are, therefore, required to withhold the normal tax of two per cent on such interest paid to non-resident alien individuals. Though non-resident alien corporations are liable to income tax on interest received from deposits in banks located within the United States, that portion of Treasury Decision 2623 authorizing withholding of such tax against such corporations is hereby revoked. DANIEL C. ROPER, Commissioner. Approved : W. G. McADOO, Secretary of the Treasury. (T. D. 2654.) Internal Revenue Claims. Modified Procedure for Claims for Refund and Abatement. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, February 19, 1918. To Collectors of Internal Revenue: The following modifications in the procedure with regard t« claims on Forms 46, 47, 53 and 488 is prescribed. 1. Claims on Form 46 and Form 47 will not hereafter be referred to division deputies for investigation, and the divi- sion deputy's certificate on page 2 of the claims need not be executed. Where an investigation is necessary it will be directed by the commissioner to be made. 2. All claims on Forms 46 and 47 are to be stamped with the date of receipt immediately on presentation to the collec- tor or division deputy, and thereafter are to be forwarded, without further recording or certification, immediately to the commissioner. Two Exceptions to this Rule Are to be Especially Noted. (a) The certificate on page 2 of the claim is to be executed in the case of claims for taxes paid by special tax stamp, since there is no data in the commissioner's office which will per- mit the verification of these claims without the collector's certificate. (b) When a claim is filed for abatement such notation is to be made on the collector's assessment list on Form 23, as will 1204 the issuance of collection notices until after the abatement claim has been acted upon, unless of course the collector deems the interests of the Government insufficiently protected to justify suspension of the collection. 3. The use of Record No. 22 is to be abandoned. Record No. 23 will continue to be used, as at present. 4. Form No. 7213, notification of allowance of refunding claim, will not longer be forwarded to collectors. 5. Hereafter where an abatement claim is acted upon, the collector will receive an original letter addressed to the claim- ant and a carbon copy for the collector's files. The original is to be mailed the claimant immediately with notice and demand for the payment of any tax shown by the letter and the assessment list to be due. 6. Where the claim is allowed in full, credit for the abated tax is not to be taken by the collector until the receipt of schedule on Form 3220. This schedule will be prepared and mailed to the collector monthly, as heretofore. 7. Because of the distribution of the claims work to the various divisions of the bureau, it is no longer practicable to consider a claim on Form 46 or 47, 5^ or 488, covering taxes assessed upon more than one of the lists of the various classi- fications. In presenting their own claims on Forms 53 and 488, therefore, collectors will hereafter group in their claims the items which are upon the list, or lists, of a given class, and if a claimant makes claim on Form 46 or 47 for the re- mission or refund of taxes assessed upon more than one kind of list, the collector will assist the claimant in formulating new claims correctly prepared. Regulations Nos. 2, 14 and 33 (Art. 247-273) are modified accordingly. The purposes of the modification of the former procedure with regard to claims are to eliminate a duplication of detail in the collector's and the commissioner's office, and the accom- modation of the taxpayer by making it possible for him to secure a much more prompt consideration of his claims than has been possible heretofore. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved : W. G. McADOO, Secretary. (T. D. 2659.) Basis of taxation of dividends. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, February 28, 1918. To Collectors, Internal Revenue Agents and others concerned: From inquiries reaching this office, it is apparent that there is confusion in the minds of the public as to the effect and application of the provisions of Section 31 of the Act of Sep- tember 8, 1916, added by the Act of October 3, 1917, Section 1211, relative to the basis of taxation of certain dividends. That section, after defining dividends, provided that "any dis- tribution made to the shareholders or members of a corpora- 1205 tion * * * in the year 1917, or subsequent tax years, shall be deemed to have been made from the most recently accumu- lated undivided profits or surplus, and shall constitute a part of the annual income of the distributee for the year in which received, and shall be taxed to the distributee at the rates prescribed by law for the years in which such profits or sur- plus were accumulated * * *." Regulations No. 33 (Revised), Article 107, paragraph 375, provide as follows: "Thus, if a corporation distributed dividends in 1917, such dividends will be deemed to have been paid from the earnings of 1917, and the recipient, if an individual, will be liable to additional tax, if any, and if a corporation, to income tax, at the rates for the year 1917, unless it is shown to the satis- faction of the Commissioner of Internal Revenue that at the time such dividends were paid, the earnings up to that time were not sufficient to cover the distribution, in which case the excess over the earnings of the taxable year will be deemed to have been paid from the most recently accumulated surplus of prior years, and will be taxed at the rate or rates for the year or years in which earned." The rule may be applied as follows: Assume that a cor- poration with a capital stock of $10,000,000 had surplus earn- ings of $500,000 a year in excess of the amount of dividends paid, making its total surplus on December 31, 1915, $500,000, and on December 31, 1916, $1,000,000. On December 31, 1916, it declared a dividend of 2% payable February 15, 1917. Unless it is shown to the satisfaction of the Commissioner of Internal Revenue that its earnings from January 1 to February 15 were insufficient for the payment of the $200,000 distributed as a dividend on February 15, the entire amount so distributed will be deemed to have been paid from earnings of 1917, and will be taxable in the hands of the stockholders at the 1917 rate. If, however, it is established to the satisfaction of the Commissioner of Internal Revenue that its earnings up to February 15 were but $100,000, then $100,000 or half of the total dividend paid by the corporation on February 15th would be taxable in the hands of the stock- holders at the 1917 rates, and the other half would be deemed to have been paid from the surplus of the corporation of 1916 and would be taxable to the stockholders at the 1916 rate. If the dividend paid on February 15 were of such amount as to exceed the ascertained 1917 earnings up to the date of pay- ment and also the 1916 surplus of the corporation, the amount of such excess would be deemed to have been paid from the surplus of 1915 and would be taxable in the nands of the stockholders at the 1915 rate. All dividends received in 1917, even though paid by corpora- tions from earnings of previous years, constitute income to the recipients for 1917. The method of ascertaining the pre- cise rate applicable to such portions of dividends received in 1917, as within the above rules, are to be taxable at rates pre- vailing for previous years, is as follows:. The amoimt of the income of the recipient to which the 1917 rates are applicable is first ascertained. To such amount is then added the amount of income of the recipient liable to tax at the 1916 rates and the table of 1916 rates applied to see in which brackets such income falls; the income liable to 1915 rates then added and the table of 1915 rates applied to it. For instance, an indi- 1800 vidual has $20,000 of income liable to 1917 rates and $25,000 of dividends liable to 1916 rates. The total would be $45,000, of which $20,000 would be taxable at the 1917 rates, $20,000 to $40,000 at the 1% additional tax rate under the 1916 table and $5,000 at the 2% additional tax rate under the same table. If he had another $25,000 dividend liable at 1915 rates, the first $5,000 would fall in the bracket between $20,000 and $50,000 at the 1% additional tax rate, and the other $20,000 in the second bracket of $50,000 to $75,000 at the 2% addi- tional tax rate under the 1915 table. In order that this office may verify the correctness of the rates, taxpayers reporting dividends received at other than 1917 rates, under the various columns in Block F of Form 1040, will be required to render a statement at the time of filing the return, or at a subsequent date, showing the cor- porations from which dividends taking other than 1917 rates were received, with the amount of dividend received from each. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved : W. G. McADOO, Secretary of the Treasury. (T. D. 2660.) Corporations, partnerships, or individuals paying officers or business employees a portion or all of their salaries and wages during the war period in which they are in the service of the United States may deduct the amounts so paid as ordinary and necessary expenses of doing business. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, March 1, 1918. To Collectors of Internal Revenue and others concerned: Many corporations, partnerships and also individuals who are engaged in business continue to pay all or portions of the regular compensation of officers or employees who have for all or part of the period of the war joined the naval or military forces of the United States or have undertaken service for the Government at Washington or elsewhere at reduced or nominal compensation. The business purpose of the continu- ance of such compensation, under such circumstances, is to preserve the organization and secure the return after the war of such officers or employees. You are advised that amounts so expended by corporations, partnerships or individuals en- gaged in business constitute during the continuance of the war, ordinary and necessary expenses of doing business and are allowable as deductions in computing net income for purposes of the income, war income and excess profits taxes. DANIEL C. ROPER, Commissioner. Approved : W. G. McADOO, Secretary of the Treasury. 1807 (T. D. 2661.) CORPORATION TAX— DECISION OF COURT. 1. Section 3225, Revised Statutes. The plaintiff having understated in its original return the amount for which it was subject to tax is not entitled to recover any part of a second assessment paid, although the original return was made in good faith and without any intention to escape lawful tax. 2. Amendment to Section 3225, Revised Statutes. The amendment to Section 3225, Revised Statutes (Sec. 14, Act of September 8, 1916), providing that it shall not apply to statements or returns made or to be made in good faith regarding annual depreciation of oil or gas wells and mines, does not purport to be retroactive in its opera- tion. 3. Judgment Aflfirmed. The judgment of the United States District Court (T. D. 2366) is affirmed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, March 5, 1918. The appended decision of the United States Circuit Court of Appeals for the Eighth Circuit, in the case of Camp Bird (Ltd.) V. Frank W. Howbert, collector of internal revenue, is published for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved : W. G. McADOO, Secretary of the Treasury. United States Circuit Court of Appeals, Eigrhth Circuit. No. 4939— December Term, 1917. Camp Bird (Ltd.), a corporation, plaintiff in error, v. Frank W. Howbert, as collector of internal revenue within and for the district of Colorado, defendant in error. In error to the District Court of the United States for the district of Colorado. Before Garland, Circuit Judge, and Amidon and Munger, District Judges. Munger, District Judge, delivered the opinion of th» court : This action was brought by plaintiff In error, hereafter called plaintiff, against defendant In error, as collector of Internal revenue of the United States for the district of Colorado, hereafter called defendant. The object of the action was to recover sums of money that plaintiff had paid to defendant as an internal revenue tax. A jury was waived and the trial court entered judgment upon special findings of facts, dismissing plaintiff's action. Briefly stated, the court found that the plaintiff was the owner of valuable and productive mining property In Col- ado, after the year 1902, and that it made a return for each of the years 1909, 1910 and 1911 to the collector of internal revenue, purporting to set forth its income for each of those years, under the provisions of the act of Congress approved August 5, 1909 (36 Stat., 112), relating to an excise tax on corporations. In these returns the plaintiff stated the items of charge and credit and the net annual Income which it considered subject to tax. The Commia- sioner of Internal Revenue found that deductions claimed In each of these returns had been overstated, and that th« 1208 amount subject to tax had been understated, and made additional assessments against the plaintiff and notified it of his action. The plaintiff, under protest, paid the additional taxes levied. An application to the Commis- sioner of Internal Revenue for an abatement of the addi- tional tax was denied by the commissioner, and this action waa then begun. While the court found that the plaintiff had understated its net income upon which it was re- quired to pay the excise tax, it was further found that the understatement was not made fradulently, knowingly, wilfully, nor for the purpose of defrauding the United States, but was made in good faith and with the belief that the figures presented stated the facts. The only question in the case is whether the Judgment is supported by these findings. Section 3225 of the Revised Statutes as it existed at the time these taxes were levied and collected was as follows: When a second assessment is made in case of any list, statement, or return, which in the opinion of the collector or deputy collector was false and fraudulent, or contained any understatement or undervaluation, no taxes collected under such as- sessment shall be recovered by any suit, unless it is proved that the said list, statement, or return was not false nor fraudulent, and did not contain any understatement or undervaluation. It is contended that this section was meant to be ap- plied only to those who intentionally made false state- ments or undervaluations, because when this act was passed an accurate statement of the facts required in returns by taxpayers could be made, whereas returns under the corporation tax law necessarily must be esti- mates. By the acts of Congress approved June 30, 1864 (13 Stat., 223), as amended and supplemented by the acts of Con- gress of March 3, 1865 (13 Stat., 469), of July 13, 1866 (14 Stat., 98), and March 2, 1867 (14 Stat., 471), a general system of internal revenue was provided to meet the financial burdens imposed by the Civil War. Taxes were imposed generally upon property, occupations, industries and incomes. Many classes of persons subject to taxation were required to make sworn lists or returns of property subject to tax. The values of property were to be re- ported and amounts of net income, and the accurate state- ment of many of the items required were quite as difficult as the ascertainment of the required items under the present corporation tax. Section 14 gave the assessor power to summon a declarant and to examine him and hi« books, if in his opinion the return was either false or fraudulent or contained any understatement or under- valuation. If the return was false or fraudulent, the assessor was required to increase the tax by 100 per cent. An unexcused neglect or refusal to make or to verify a list was penalized by the addition of 50 per cent to the tax. By Section 20 the assessor was empowered to fix the amount of additional tax to be paid, when there had been an omission, understatement, undervaluation or false oi fraudulent statement. Section 44 authorized the Commis^ sioner of Internal Revenue to refund excessive taxes col- lected and to repay to collectors amounts recovered in court against them for taxes collected by them, but provided that no taxes should be recovered, refunded or paid back, where a second assessment had been made because the first list had been, in the opinion of the assessor, either false, fraudulent, or contained any understatement or undervaluation, unless it was proved that the return was not false or fraudulent, or did not contain any understate- ment or undervaluation. The substance of these enact- ments has continued in force ever since. (See Rev. Stats., Sees. 3173, 3176, 3182, 3220, 8225; U. S. Comp. Stats. Ann., Sees. 5896, 5899, 5904, 5944, 5048). They evince a discrimi- nating use of terms as between false and fraudulent re- turns and those that contain only an understatement or valuation, and provide remedies and penalties apportioned to the several delinquencies. The mere undervaluation or understatement in a return is made a basis for sum- moning the delinquent to appear and be examined and a basis also for imposing an additional- as- sessment, and prevents the Commissioner of Internal 1209 Revenue from making a refund or remission of taxes. The further provision found In Section 3225 of the Revised Statutes, denying recovery by suit of any tax imposed under a second assessment, because In the opinion of the collector or his deputy, the former return was false or fraudulent or contained an understatement or undervalua- tion, unless It is proved that the prior list was not false nor fraudulent nor contained any understatement nor undervaluation, Is in harmony with these provisions, and manifest the intention of Congress that no recovery may be had although the undervaluation or understatement was made unintentionally. See Bergdoll r. Pollock (95 U. S., 837). The proposition Is advanced that this construction of Sec- tion 3225 renders It violative of the Constitution, as it would result in the confiscation of plaintiff's property. It is well settled that "this corporation tax act imposed an excise tax and the only limitation on the power of Congress in the imposition of excise taxejs is that they shall be uniform throughout the United States." United States V. Singer (15 Wall., Ill, 121) : Pacific Insurance Co. V. Soule (7 Wall., 433, 446). By this a geographical uni- formity is meant. Flint v. Stone Tracy Co. (220 U. S., 107). The provisions laying an additional tax proportionate to the pi-operty omitted from the list on all who make any understatement or undervaluation operates uniformly on all of that class of persons wherever found and hence was within the power of Congress. The re- fusal of a right of action to recover such taxes, unlesi proof is made that there was no understatement or under- valuation is likewise within the scope of the legislative power. It is claimed that "Section 3225, Revised Statutes, does not apply to the suit for the recovery of taxes col- lected under the corporation tax of 1909. This section ap- plies to internal revenue taxes generally" and the corpora- tion tax is one embraced in that class. In addition the corporation tax law contained a clause as follows (p. 951 Bupp. to U. S. Comp. Stats., 1911): All laws relating to the collection, remission, and refund of internal revenue taxes, so far as ap- plicable to and not inconsistent with the provisions of this section, are hereby extended and made ap- plicable to the tax imposed by this section. We think that Section 3225, Revised Statutes, Is a part of the laws relating to the refund of internal revenue taxes, as Section 3220, Revised Statutes, provides that the Commissioner of Internal Revenue is authorized to refimd to the collector any amount that may be recovered against him in any court for any internal taxes collected by him. Plaintiff also contends that the Judgment is erroneous, because after final Judgment was entered in this case Con- gress enacted an amendment to Section 3225, Revised Stat- utes, which reads (p. 6984, 6 U. 3. Comp. Stats., Ann.) : "♦ ♦ • But this section shall not apply to statements or returns made or to be made in good faith under the laws of the United States regarding annual depreciation of oil or gas wells and mines." This statute does not purport to be retroactive in Its operation and hence can not affect the Judgment in this case. This disposes of all questions that require con- sideration. The Judgment will be affirmed. (T. D. 2662.) When consolidated returns are to be made for purposes of the excess profits tax. Treasury . Department, Washington, D. C, March 6, 1918. To Collectors of Internal Revenue, Rerenue Agents and Others Concerned : Pursuant to Article 78 of Regulations 41 relative to war excess profits tax, afi'iliated corporations as limited and de- 1810 fined in paragraphs C and D below are hereby directed to make consolidated returns for the purpose of excess profits tax. Affiliated corporations other than those falling within the provisions of paragraphs C and D may make a consolidated return only after having secured permission in writing from the Commissioner of Internal Revenue. Affiliated corporations are defined in Article 77 of the Regulations as follows: For the purpose of this regulation two or more cor- porations will be deemed to be afRliated (1) when one such corporation owns directly or controls through closely affiliated interests or by a nominee or nom- inees, all or substantially all of the stock of the other or others, or when substantially all of the stock of two or more corporations is owned by the same indi- dividual or partnership, and both or all of such cor- porations are engaged in the same or a closely re- lated business; or (2) when one such corporation (a) buys from or sells to another products or serv- ices at prices above or below the current market, thus effecting an artificial distribution of profits, or (b) in any way so arranges its financial relationships with another corporation as to assign to it a disproportion- ate share of net income or invested capital. A. Two or more corporations are not "affiliated" merely be- cause all or substantially all of the stock therein is owned by the same corporation, individual or partnership; they must also be engaged in the same or a closely-related business. B. For purposes of regulation by public service commissions or similar authorities the identity of public service corpora- tions, when not grouped into one operating unit, must be main- tained, even though they are owned by the same corporation or taxpayer; and under such regulation the accounts of such public service corporations are deemed to reflect the true in- vested capital and income of each operating unit. Accordingly railroads, gas, electric, water and other public service corpora- tions when operated independently and not physically con- nected or merged — particularly when situated in different juris- dictions and subject to regulation by public service commis- sions — will not be required or permitted without special per- mission obtained in advance to make a consolidated return. When, however, a railroad or other public utility is owned by an industrial corporation and is operated as a plant facility or as an integral part of a group organization of affiliated cor- porations, and such affiliated corporations are required to file a consolidated return,. the return of such railroad or other public utility shall be included therein. C. The words "all or substantially all of the stock" as used in the above definition (Article 77) will until further notice be interpreted as meaning an ownership of 95 per cent or more of such stock by the same taxpayer during the taxable year. D. In case of affiliated corporations among which there exist contracts or trade or financial practices which arbitrarily or artificially influence or determine the amount of the invested capital or net income of one or more of the corporations so affiliated and where 95 per cent or more of the stock of the subsidiary afliliated corporations is owned by a parent or con- trolling corporation or by an individual or partnership, a con- solidated return will be required. E. A consolidated return shall be filed by the parent or principal corporation in the office of the collector of the district in which it has its principal office. Each of the other affiliated corporations shall file in the office of the collector of its re- 12X1 spective district a return, entering thereon its name and address and replying to the questions in Schedule I, and to questions 1, 2, 3, 4 and 11 on page 4 of Form 1103; and stating also (1) that the corporation is affiliated with a designated parent or principal corporation, (2) that its return is included in the consolidated return of such parent or principal corpora- tion, and (3) the district in which the consolidated return is filed. F. Assets of affiliated or subsidiary corporations which have to be adjusted to meet the statutory limitation prescribed by Section 207 shall be valued as of conditions existing at the dates when such assets were acquired by the respective affi- liated or subsidiary corporations and not as of the date when the stock in such affiliated or subsidiary corporations was acquired by the parent or controlling corporation. G. Affiliated corporations filing a consolidated return shad include in such return (1) a specific statement of the number or proportion of the shares in the affiliated corporations held by the parent or controlling corporation during the taxable year, and (2) a schedule showing the proportionate amount of the total tax which it is agreed among them is to be assessed upon each affiliated corporation. H. If the Commissioner of Internal Revenue upon examina- tion of any consolidated return finds that the tax can not in hii judgment be properly assessed upon the basis of such return, the affiliated corporations covered by such consolidated return shall, upon notice from the Commissioner of Internal Revenue, file separate returns. DANIEL C. ROPER, Commissioner of Internal Revenue, (T. D. 2663.) Method to be followed in crediting an overpayment of the two per cent income tax by a corporation filing supplemental return for a fiscal year ended on the last day of some month during the year 1917, or a "fiscal" return for a period ended during such year. Treasury J)epartment, Office of Commissioner of Internal Revenue, Washington, D. C, March 8, 1918. To Collectors of Internal Revenue: Under the Act of September 8, 1916, as originally passed, corporations were entitled to take as a deduction all taxes paid. Under the same Act as amended by the Act of October 3, 1917, they are not entitled to any deduction for income tax paid, but are entitled to a credit of the amount of excess profits tax for which they are liable. They are also liable for the war income tax of 4% imposed by the Act of October 3, 1917. It follows, therefore, that a corporation which has filed re- turn for a fiscal year ended on the last day of some month during the year 1917, or a "final" return for a period ended during such year showing its liability computed under the Act of September 8, 1916, as originally passed, must make an amended return showing additional net income (in an amount 1213 I equal at least to the amount of income tax deducted in its original return). It will also take credit for the amount of excess profits tax, if any, for which it is liable. This will ordinarily result in showing an overpayment of income tax at the 2% rate, and the amount of such overpayment may be credited against the war income tax of 4% for which liable, to ascertain the total amount of income tax due. In no case will a credit for overpayment of income tax be taken against the excess profits tax due. The adjustment should be made under items 13 to 15, in- elusive, and the exact amount of tax due from the corpora- tion must be shown under item 16 of return, Form 1031, re- vised. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved : W. G. McADOO, Secretary of the Treasury. (T. D. 2665.) Amending T. D. 2153. Instructions governing the preparation of income tax returns by farmers. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, March 8, 1918. To Collectors of Internal Revenue: The term "farm" as herein used embraces the farm in the ordinarily accepted sense and includes plantations, ranches, stock farms, dairy farms, poultry farms, fruit farms, truck farms, and all land used for similar purposes; and for the purposes of this decision all corporations, partnerships, or in- dividuals who cultivate, operate, or manage such farms for gain or profit, either as owners or tenants, are designated as "farmers." All gains, profits and income derived from the sale or ex- change of farm products, whether produced on the farm or purchased and resold by the farmer, shall be included in the return of income for the year in which the products were actually marketed and sold. All items of expense connected with the planting, cultivat- ing, harvesting and marketing of a crop, or the care, feeding and marketing of live stock may be claimed as deductions only in the return rendered for the year during which such expenditures were made. This ruling applies even though the crops or stock in connection with which the expenses were in- curred may not have been sold or exchanged for money or a money equivalent during the year for which the return is rendered. That portion of Treasury Decision 2153 and paragraph 32 of Regulations No. 33 (Revised) which provides "cost of stock purchased for resale is an allowable deduction under the item of expense," is hereby annulled. It is held that the amount expended in purchasing stock for resale is an investment of capital and is not to be taken as an item of expense for the year in which the stock was purchased, or for any subsequent 1213 year; but when the stock so purchased is sold its cost it to be deducted from the sales price in ascertaining the amount of gain or profit returnable for tax purposes. Where the cost of stock or farm products purchased in 1916, or any previous year, for resale, or the expense of producing stock or products on the farm, has been claimed as a de- duction or taken into consideration in ascertaining the farmer's liability to income tax for some year prior to 1917, and the stock or farm products so purchased or produced were sold during the latter year, the entire proceeds of the sale are to be returned as income for the year in which the sale was made, for the reason that the farmer, having once received the benefit of the deduction, is not again entitled to it. If, however, such cost or expense had not been claimed as a de- duction, or had not been taken into consideration in ascertain- ing the farmer's liability to income tax for a previous year, the amount of such cost or expense may be deducted from the selling price of the stock or farm products and the difference only returned as income. Farmers who keep books according to some approved method of accounting which clearly show the net income, and take annual inventories, may, if the same method is consistently followed from year to year, prepare their returns in accordance with the showing made by the books and inventories. If the inventory method is adopted the farmer should, in order to ascertain gross income, add to the amount received from sales made during the year the inventory of the live stock and products on hand at the close of the year and from this sum deduct the amount expended in purchasing live stock and products plus the inventory of the live stock and products at the beginning of the year. The inventory at the beginning of a tax year must be the same figure as at the close of the next preceding year and must include the cost price of live stock or products purchased for resale, and may include the live stock and products produced on the farm and still on hand. Where gross income is ascer- tained by inventories, no deduction can be made for live stock or products lost during the year, whether purchased for resale or produced on the farm, as such losses will be reflected in the inventory by reducing the amount of live stock or products on hand at the close of the year. Live stock purchased for draft, breeding or dairy purposes, or for any purpose other than resale, may be included in the inventory for each year at a figure which will reflect the reduction in value estimated to have occurred during the year through increase of age or other causes. Such a reduction in value should be based on the cost and estimated life of the live stock. In the case of the loss of such live stock no deduction can be made, as this loss will be reflected in the in- ventory at the end of the year. "Wliere the inventory method is used, the cost price of the article sold must not be taken as an additional deduction in the return of income as it is reflected in the inventory. In view of the foregoing, all corporations, partnerships, and individuals engaged in the live stock or farming business, which do not keep books of account and ascertain their gross income by inventory, should prepare their returns of annual net in- come on the basis of actual receipts and disbursements in order that their returns of income may be susceptible of audit for purposes of verification. Treasury Decision 2433 contains additional information relative to the rendering of returns 1214 of income by corporations keeping books in accordance with standard systems of accounting, or in conformity with the requirements of some Federal, State or municipal authority, having supervision over such corporations. The foregoing relates only to income derived from the opera- tion of a farm and has no relation to the gain or profit which may result from the sale of the farm. Where a farmer exchanges farm produce for merchandise, groceries, or mill products, the market value of the article or product received in exchange is to be returned as income. A farmer is not required to include in his income tax return the value of farm produce consumed by himself and family. DANIEL (J. ROPER, Commissioner of Internal Revenue. Approved : W. G. McADOO, Secretary of the Treasury. (T. D. 2666.) Handling remittances received in payment of income and excess profits taxes. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, March 8, 1918. To Collectors of Internal Revenue: Instructions to public: 1. Collectors should give the widest possible publicity, through newspapers and by all other available means, to the fact that all checks in payment of income and excess profits taxes must be collectible at par (without any deduction). Taxpayers who are not sure that their checks will be paid at par should be advised to write beneath the amount "without deduction for exchange," or "with exchange." Indorsement of checks: 2. The collector need not, however, examine all checks to see whether or not they are collectible at par, but should stamp on the face of each the words "This check is in payment of an obligation to the United States and must be paid at par. No protest," with his name and title. If the bank on which a check is drawn should refuse to pay it at par, it will be re- turned through the depositary bank and should be treated in the same manner as a bad check (see paragraphs 4 and 5). Obtaining certificates of deposit for out-of-town checks. 3. All out-of-town checks for which the depositary bank is unwilling to issue an immediate certificate of deposit to the credit of the Treasurer of the United States should be de- posited separately in a collection account as provided in T. D. 2627, dated December 28, 1917. The collection account will be charged and the Treasurer's general account credited by the issuance of a certificate of deposit on Form 15, either (a) as the checks are collected or (b) after a number of days as agreed upon with the depositary, subject to the Secretary's approval, not exceeding five days, depending upon the average time of collection. 1215 Redeeming bad checks deposited to the credit of the Treasurer. 4. If any check for which a certificate of deposit to the credit of the Treasurer of the United States has been issued should be returned to the depositary bank unpaid, the col- lector will be promptly notified and the check will be held in suspense for a few days, during which the collector should make an effort to recover the amount from the taxpayer. If the amount of the check is recovered* from the taxpayer, the collector should immediately turn it over to the depositary in exchange for the bad check, which should be returned to the drawer. If he fails to obtain the amount from the tax- payer within a reasonable time, the depositary will return the check with a letter of transmittal and ask a receipt from the collector. The collector should give such a receipt in dupli- cate, retaining one copy. The depositary will charge the amount to the Treasurer's account in its next daily transcript. Redeeming bad check deposited in collection account. 5. If a check deposited in the collection account should be returned unpaid, and no certificate of deposit on Form 15 cov- ering the amount thereof has been issued, the amount of the check will be charged by the depositary to the collection ac- count, after being held in a suspense account for a few days while an effort is made to recover the amount from the tax- payer. Collecting taxes for which bad checks have been tendered. 6. Taxpayers whose checks have been returned uncollected by the depositary bank should be immediately notified, as in- dicated in paragraph 4, to make the checks good. If any tax- payer should fail to do so, the collector should proceed to col- lect the taxes by the usual methods, as though no check had been given. Correcting assessment list. 7. If the recapitulation of the assessment list for the month has not yet been sent to the Commissioner, cancel the original entry of the payment, at the same time noting in the "Re- marks" column "Check returned unpaid ; transferred to p. , 1 ," with the date, and re-enter the item in the unpaid section of the list, with the notation "Transferred from p. , 1 ." Submit in support of a new entry a copy of the collector's letter to the taxpayer with regard to the non-pay- ment of the check. Be careful not to duplicate the charge in the monthly recapitulation of the list. 8. If the monthly recapitulation has gone forward make a note in the *Tlemarks" column, opposite the original entry, "Check returned unpaid," with the date, and let the item stand as an unpaid item to be cleared by an entry of the date on which the amount is finally paid. Posting Records 1 and 9. 9. Record 1 for income tax collections should be posted m accordance with previous instructions and the daily totals should be transferred to line 1 of Record 9. As the daily total in Record 9 will not agree with the total deposit for the day in the Treasurer's general account, the certificate of deposit numbers should not be entered on line 48 of Record 9. 10. The balance in the collection accoimt at the close of each month should be subtracted from the balance at the close of the preceding month (or vice versa). If the balance in 1216 the collection account shows an increase for the month, such increase should be added to the amount of returned checks (if any) charged back to the Treasurer's general account dur- ing the month and the total should be entered on line 8 in the total column of Record 9 in red ink, to be deducted from the other entries in the same column. 11. If the balance in the collection account shows a decrease for the month, and the amount of returned checks charged back to the Treasurer's general account for the month is less than the decrease in the balance, the amount of such returned cheeks should be subtracted from the decrease in the balance and the difference entered in black ink on line 8 in the total column of Record 9, to be added to the other entries in the same column. 12. If the amount of returned checks charged back to the Treasurer's general account for the month should exceed the decrease in the balance for the month, such decrease should be subtracted from the amount of such returned checks and the difference entered in red ink on line 8 in the total column of Record 9. 13. The net total for each month entered on line 9 of Record 9 will thus agree with the amount deposited that month on accountof collections on lists. Monthly accounts. 14. Form 325 should be prepared from Record 1 in accord- ance with previous instructions. At the close of the month the entry on line 8 in the total column of Record 9 (black or red ink) should be entered in column 8 of the second table on Form 51B, on the blank line following the line for "Old regular" lists. If the amount en- tered in column 8 is in black ink the same amount should be entered in red ink on the same line in column 11. If the amount entered in column 8 is in red ink the same amount should be entered in black ink on the same line in column 11. 15. The amount of returned checks charged to the Treas- urer's general account each month should be deducted on Form 49 from the total of the certificates of deposit for the month in which the checks are returned. The entry making the de- duction should be supported by the banks' letters returning the checks. 16. The collector should submit with his monthly account on Form 5113 a monthly statement signed by the cashier of the depositary bank in the following form: Total Amount trans- Checks amount ferred each day charged deposited to Treasurer's back each Day each day. general account. day. Balance Balance from last month's account 1 2 Etc. Quarterly account. 17. On Form 79 the balance in the collection account should be included in item 9 as part of the balance due the United 1217 states and interlined in the analysis of the balance (at the foot of the account) as "Uncollected checks." DANIEL C. ROPER, Approved : Commissioner. W. G. McADOO, Secretary. (T. D. 2668.) Salaries received under funds of Smith-Lever Act of May 8, 1914, as taxable income. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, March 9, 1918. To Collectors of Internal Revenue and Others Concerned: Section 1200 of the Act of October 3, 1917, amending Section 4 of the Act of September 8, 1916, provides, in part, that the following income shall be exempt from tax: "The compensation of all officers and employes of a State, or any political subdivision thereof, except when such compensation is paid by the United States Govern- ment." The Smith-Lever Act of May 8, 1914, makes provision for extending the benefits of the Act of Congress approved July 2, 1862 (12 Stat. 503), and the Act approved August 30, 1890 (26 Stat. 417). Under the aforesaid Act certain colleges were established in the several States and supported by the income from lands deeded to the States for that purpose. The colleges receiving the benefits of the two earlier Acts and of the Smith- Lever Act are controlled by States. The funds available under the Smith-Lever Act are appropriated by State legislatures to the colleges to be benefited thereby. The funds appropriated by the Federal Government are paid directly into the State treasuries as any other subventions by the Federal Govern- ment. They lose their identity as funds of the United States by being paid to the States. There may be considerable difference between the different States in the control and government of the colleges receiving the benefits of the Act. If the organization of the college is one which belongs to the State and which the State governs, the legislature may vacate offices, elect new professors and do whatever it thinks necessary in the management of the college. (Head vs. Univ., 19 Wall. 526). If, however, the colleges are governed by trustees who are not directly responsible to the State legislatures, the employes of the college receiving sal- aries paid in part from Smith-Lever funds are not employes of the State, and accordingly are not exempt from tax on the ground that they are employes of the State. Where the employes of universities receiving salaries paid in part or in whole from Smith Lever funds are officers or em- ployes of a State, they are not required to include in their income tax returns as taxable income the salaries so received. DANIEL C. ROPER, Approved : Commissioner. W. G. McADOO, Secretary of the Treasury. 1218 (T. D. 2669.) Revision of T. D. 2386 requiring Dutch Administration Offices as the registered but not the actual owners of stock of domestic or other resident corporations in the United States to disclose the identity of the actual owners of said stock for the purposes of the withholding provisions of Section 13 (f), Act of September 8, 1916, as amended by the Act of October 3, 1917. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, March 9, 1918. To Collectors of Internal Revenue: Dutch Administration Offices, being nonresident alien cor- porations not engagged in business or trade in the United States and not having an office or place of business therein, and be- ing the registered owners of stock of domestic or resident corporations in the United States, are prima facie liable for the normal income tax on income derived from dividends upon the capital stock or from the net earnings of the aforesaid domestic or other resident corporations in the United States and to having the tax reducted and withheld from such income under Section 13 (f). Act of September 8, 1916, as amended by the Act* of October 3, 1917. It appearing that the Dutch Administration Offices, while the registered owners of stock as aforesaid, are not the actual owners thereof, but that they have issued their oearer cer- tificates, with coupons attached, against said stock and that the dividends on said stock are collected for the account of the holders of said bearer certificates and that the relation sus- tained by said Dutch Administration Offices to the said bearer certificate holders is that of fiduciary; for the purposes of administration under the withholding provisions of Section 13 (f). Act of September 8, 1916, as amended by the Act of October 3, 1917, the respective Dutch Administration Offices may each appoint an agent or agents in the United States and give notice of that fact by filing, in duplicate, with each cor- poration issuing the stock so held by said Dutch Administra- tion Office, a notice in substantially the following form, to be signed by the proper executive officer: You are hereby advised that (Name and address of the Dutch Administration Office) the registered owner of stock in has appointed (Issuing corporation) whose (Name of agent) address is , as its agent in the United States; and that the undersigned and said agent will not pay any of the dividends received by them to or for the benefit of any enemy or ally of enemy of tne United States of America as defined in the Trading with the Enemy Act of October 6, 1917. Upon receipt of notice as aforesaid, the debtor or issuing corporation in the United States shall pay over to said Dutch 1219 Administration Office or its agent in the United States all taxes previously withheld from dividends and all subsequent dividends without withholding any tax, and shall forward to the Commissioner of Interhal Revenue one copy of the said notice of the appointment of the agent in the United States. It will be necessary to file this notice but once, unless there shall be a change of agent, when a similar notification should be given. When it shall appear that a Dutch Administration Office has an agent in the United States and when, because of that showing, dividends of domestic or other resident corporations in the United States shall have been paid to it or its agent without withholding of tax, said Dutch Administration Oltice through its agent in the United States will be required to make annual return thereof in duplicate and pay the normal tax found by such return to be due, as follows: (1) Where it shall be disclosed by ownership certificates, as hereinafter provided, that the actual owner of any said stock on which such divi- dends are paid is a nonresident alien corporation, and (2) Where there is no disclosure of the actual owners of any of said stock by such ownership certificates. No return need be made nor tax withheld and paid for any nonresident alien individual, firm or partnership unless and until the agent in the United States shall be so instructed by the Commissioner of Internal Revenue. Required returns shall be made in duplicate and filed with the Collector of Internal Revenue for the district in which the agent has its office or principal place of business, and shall be in the following form: Form — , United States Internal Revenue. Dutch Administration Offices — Income tax return on dividends received from domestic and resident alien corporations. For the year ended December 31, 19 — . Filed by (Name and adaress of Dutch Administration Office.) I (We) of (Name of Agent). (Address). duly appointed agent in the United States of said do hereby declare that herewith are (Name of Dutch Administration Office). enclosed all ownership certificates received during the year above mentioned, disclosing the actual owners of the stock registered in its name in the following domestic and resident alien corporations and covering dividends received and paid during said year: Name of Corporation Address in full Dividends Received Balance from last return Total 1220 That the following is a true and complete return of all pay- ments so disclosed of said dividends, and the normal tax with- held and to be paid thereon: Dividends received and balance from last return as above $ Dividends paid as per enclosed certificates Tax To nonresident alien individuals and firms $ (On which no tax is due from Dutch Admin. Office) To nonresident alien corporations $ $ (On which tax at 2% is to be paid). To owners not disclosed $ $ (On which tax at 2% is to be paid). Balance unpaid to be accounted for in next return Total tax to be paid $ I certify that no part of the dividends shown in the above statement was paid to or for the benefit of any enemy or ally of enemy of the United States of America as defined in the Trading with the Enemy Act of October 6, 1917. Agent. To (Collector). District of This item refers to amount of dividends received but not paid over to actual owners at time last return, if any, was rendered. Said returns shall be printed on yellow colored paper cor- responding in weight and texture to white writing paper 21x32, about 40 pounds to the ream of 500 sheets, and shall be 8Va inches wide and 14 inches from top to bottom. The ownership certificates for disclosing the actual owners of stock shall be in Form 1087 Revised, prescribed by T. D. 2401; provided, however, that the ownership certificates form- erly permitted to be used by the several Dutch Administra- tion Offices, and executed prior to the date of this decision, may be filed with their above provided returns and made the basis thereof. This certificate shall be filed with the Dutch Administration Office by the person, firm or corporation, etc., or their agent, for whom and in whose behalf it acts. A cer- tificate once filed, disclosing said actual owner, will be held to answer for all the requirements under this Regulation until the ownership shall change, when it will be necessary to dis- close the actual owner as in the first instance. All such cer- tificates filed with the several Dutch Administration Offices shall be forwarded to their respective agents in the United States to be filed with their return. T. D. 2386 is revised accordingly and all Treasury Decisions in conflict herewith are hereby superseded and repealed. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: W. G. McADOO, Secretary of the Treasury. 1221 (T. D. 2670.) Information at source. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, March 11, 1918. To Collectors of Internal Revenue and Others Concerned: Section 1211 of the War Revenue Act amends the Act of September 8, 1916, by adding to Part III, Section No. 28, which provides : "That all persons, corporations, partnerships, associa- tions, and insurance companies, in whatever capacity act- ing, including lessees or mortgagors of real or personal property, trustees acting in any trust capacity, executors, administrators, receivers, conservators, and employers, makihg payment to another person, corporation, partner- ship, association, or insurance company, of interest, rent, salaries, wages, premiums, annuities, compensation, re- • muneration, emoluments, or other fixed or determinable gains, profits, and income * * * of $800 or more in any taxable year, or, in the case of such payments made by the United States, the officers or employes of the United States having information as to such payments and required to make returns in regard thereto by the regulations hereinafter provided for, are hereby authorized and required to render a true and accurate return to the Commissioner of Internal Revenue, under such rules and regulations and in such form and manner as may be pre- scribed by him, with the approval of the Secretary of the Treasury, setting forth the amount of such gains, profits, and income, and the name and address of the recipient of such payment: * * *" This section makes it mandatory for all persons, corpora- tions, partnerships, and associations or insurance companies, in whatever capacity acting, including lessees or mortgagors of real or personal property, trustees acting in any trust capacity, executors, administrators, receivers, conservators, and employers, making payments of $800 or more of income to another person, corporation, partnership, association, or in- surance company, in the calendar year 1917, to file information return of such payments in accordance with rules and regula- tions prescribed by the Commissioner of Internal Revenue, with the approval of the Secretary of the Treasury, or become liable for a penalty of not less than $20 or more than $1,000. To this end certificate, form No. 1099, and letter of transmittal, form No. 1096, have been provided for use in reporting such payments. Under the above authority the following instructions are issued for the guidance of all concerned: PAYMENTS MADE WHICH DO NOT REQUIRE REPORTS OF INFORMATION. Payments made to corporations, associations, or insurance companies for the year 1917. Bills paid for merchandise, telegrams, telephone, freight, storage, and similar charges. Bills paid to employes for board and lodging while traveling xinder orders or when employe is employed on a salary basis. Payments of premiums made to insurance companies for annual protection. Annuities representing return of corpus or capital. Fees to lawyers, doctors, and similar payments, aggregating less than $800 for the year. Interest accrued on bank deposits, before it has been passed to the credit of the individual depositor. Salary, wages, and other compensations for services rendered in December, 1917, but paid in 1918, unless the amount was fully due and passed to the credit of the individual in Decem- ber, 1917. Payments of rent made to real estate agents. (But agent must report payments to landlord, if the same amounts to $800 or more during 1917.) . Payments made to employes in factories where the brass check or number system was in use during 1917, and a record of sufficient detail does not exist and cannot be obtained be- cause employes are not longer in the employ of the company. However, in all such cases an accounting system must be in- stalled that will enable such employers to keep an accurate check so that full information can be given in the future. "Living quarters" referred to in paragraph 235, Regulations No. 33 (revised) are quarters furnished for the benefit and con- venience of employes only. When living quarters, such as camps, are furnished for the convenience of the employer only, the cost need not be added to the compensation of the em- ploye. In the case of an employer having a large number of em- ployes who are moved from place to place as the exigencies of the service require, and who consequently has no complete record of annual payments to them at any one place, the salary of two representative months may be taken to establish a fair monthly wage, and unless yearly payment based on this esti- mate in the case of an employe amounts to $800 or more no return of payments to such employe is required for 1917. Payments made by branches of business houses located in foreign countries to alien employes serving in forgein countries need not be reported. Returns of information will not be required from disbursing officers of payments made to sailors, soldiers, or civilian em- ployes of the United States Government, the records in these cases being available to the Treasury Department at any time. GENERAL INSTRUCTIONS. Heads of branch offices and sub -contractors employing labor and keeping the only complete record of payments snould file the returns of information in regard to such pa-yments direct with the Commissioner of Internal Revenue, Sorting Division, Washington, D. C. When the record is kept of payments at both the main office and the branch office the return should be filed by the main office. Where no address is available, the last known post office address must be given. Street and number should be given when possible. Information in regard to whether an employe is single, head of a family, or married, should be given when possible. DANIEL C. ROPER, Approved : Commissioner. W. G. McADOO, Secretary of the Treasury. (T. D. 2671.) Corporation Tax Act of August 5, 1909 — Decision of United States Circuit Court of Appeals — 1. Interest on Bonds — Interest on bonds or other indebtedness is an allowable de- duction from gross income only to an amount paid upon bonded or other indebtedness not exceeding the corporation's paid-up capital gtock. 2. Organized for Profit — The plaintiff was incorporated to provide and operate a terminal for certain railroads; profit was one of the sub- stantial objects of its organization and that is enough to bring it within the statute. 3. Judgment of District Court, District of Massachusetts (T. D. 2428), is afiirmed. Treasury Department, Office of the Commissioner of Internal Revenue, Washington, D. C. The appended opinion of the United States Circuit Court of Appeals for the First Circuit in the case of the Boston Termi- nal Company vs. James D. Gill, Collector, is published for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. (T. D. 2672.) Treasury Department, Office of the Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: The provisions of T. D. 2581, dated November 10, 1917, shall apply to returns by American citizens residing or travel- ing abroad, including persons in the military or naval estab- lishments of the United States stationed or on duty beyond the limits of the States and the Territories of Hawaii and Alaska. Any such person filing his return after April 1, 1918, but on or before October 1, 1918, embodying therein or attaching thereto a written statement showing that he comes within the classes designated by T. D. 2581, is relieved of the necessity of filing the supporting affidavit required by that decision. The above ruling also applies to War Excess I^rofits Tax returns. DANIEL C. KOPER, Commissioner of Internal Revenue. Approved March 16, 1918. 1224 (T. D. 2673.) Extending time for filing returns of income by or for enemies and allies of enemies as defined in the Trading with the Enemy Act. Treasury Department, Office of the Commissioner of Internal Revenue, Washington, D. C, March 18, 1918. To Collectors of Internal Revenue, Internal Revenue Agents and Others Concerned: An extension of time is hereby granted for such period as may be necessary, not exceeding ninety days after proclama- tion by the President of the United States of the end of the war with Germany, for filing returns of income for 1917 and subsequent years under Section 6(c), 8(b) (c) and 13(b) (c) of the Income Tax Act of September 8, 1916, as amended, and under the War Income Tax Act of October 3, 1917, by or for enemies or allies of enemies, as defined by Section 2 of the Trading with the Enemy Act of October 6, 1917, not holding a license granted under the provisions of said Act; provided, however, (1) that return of information shall be made in compliance with Section 28 of the Income Tax Act, and (2) that all persons required to withhold the normal tax pur- suant to Sections 9 (b) and 13 (e) (f) of the Income Tax Act shall make due return and payment thereof for the period ending October 6, 1917, in respect of income paid over before such date to or for any such enemies or allies of enemies, and further (3) that, except for such payment, all persons who on October 6, 1917, had, or since have had, or may hereafter have, control of any money or other property for any such enemy or ally of enemy, or who on October 6, 1917, were, or since have been, or may hereafter be, indebted to any such enemy or ally of enemy, (a) shall hold and deliver all said money and property in all respects subject to said Trading with the Enemy Act and to the orders of the President of the United States and of the alien property custodian thereunder, and (b) shall in due course file returns of income in respect of all said money and property for such period as may elapse or have elapsed prior to the actual delivery of said money and property to said alien property custodian. DANIEL C. ROPER, Commissioner of Internal Revenue. (T. D. 2674.) AMENDED INSTRUCTIONS RELATIVE TO THE REPORT- ING OF INTEREST ALLOWED ON PAYMENTS OF INCOME AND EXCESS PROFITS TAXES. Treasury Department, Office of the Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue: T. D. No. 2622 is amended as follows: The amount of interest allowed on income and excess profits taxes paid in advance should not be entered on the receipt form, but only ou the face of the return. The date from 1225 which interest is allowed should also be entered on the re- turn, if different from the date of deposit of the remittance. The amount of interest allowed must be entered on the orig- inal notice of assessment when it is paid, and also on the filing the supporting aflSdavit by that decision. Interest allowed on advance payments should not be entered on the assessment list. Interest allowed on assessed taxes should be entered in the "remarks" column of the list. A schedule of interest allowances should be submitted for as- sessed taxes only. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved March 18, 1918. (T. D. 2677.) Cases in which partnerships may file returns on basis of fiscal year. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue, Revenue Agents and Others Concerned: In any case where a partnership keeps its books upon the basis of a fiscal year ending on the last day of any month, other than December 31, and where as a result it is imprac- ticable to make a satisfactory return for purposes of the excess profits tax upon the basis of the calendar year, the Collector of Internal Revenue may accept a return upon the basis of its fiscal year even though notice was not given within the time prescribed in T. D. 2632, dated January 21, 1918. If in any such case a partnership has already filed a return upon the basis of the calendar year the collector may accept an amended return upon the basis of its fiscal year. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: March 23, 1918. WM. G. McADOO, Secretary of the Treasury. (T. D. 2678.) Corporations may distribute earnings for an accounting period ratably over the period for the purpose of ascertaining earnings to date of dividend payment within such period. Treasury Department, Office of Commissioner' of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue: In view of the difficulty which many corporations are hav- ing in determining whether earnings in 1917 up to the date of a dividend payment in that year were sufficient to cover 1226 the dividend paid, it is held that in any case where there is doubt upon the point, corporations may distribute the earnings for the accounting period within which the dividend, or dividends, in question were paid, ratably over the period, for the purpose of determining the amount of the earnings during the period up to the date of payment. This should be read in connection with instructions set forth in T. D. 2659. DANIEL C. ROPER, Commissioner. Approved: March 23, 1918. WM. G. McADOO, Secretary of the Treasury. (T. D. 2679.) Income Tax Payments: Five Per Cent Penalty and Interest. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue: By Section 9(a) of the Act of September 8, 1916, it is pro- vided with respect to the income taxes of individuals, as follows : "and to any sum or sums due and unpaid after the fifteenth day of June in any year, and for ten days after notice and demand thereof by the collector, there shall be added the sum of five per centum on the amount of tax unpaid, and interest at the rate of one per centum per month upon said tax from the time the same became due, except from the estates of insane, deceased, or insolvent persons." By Section 14(a) of said Act it is provided with respect to the income taxes of corporations, joint stock companies, associations and insurance companies, as follows: "and to any sum or sums due and unpaid after the fifteenth day of June in any year, or after one hun- dred and five days from the date on which the return of income is required to be made by the taxpayer, and after ten days' notice and demand thereof by the col- lector, there shall be added the sum of five per centum on the amount of tax unpaid and interest at the rate of one per centum per month upon said tax from the time the same becomes due." By Section 212 of the Act of October 3, 1917, it is provided with respect to excess profits taxes that "all provisions of Title I of such Act of September eighth, nineteen hundred and sixteen, as amended by this Act, relating to returns and payment of the tax herein imposed, including penalties, are hereby made applicable to the tax imposed by this title." By reason of absence in foreign countries or on account of traveling abroad, or of absence from their homes or places of business in the military or other service of the country, and 1227 the consequent delay in receiving mail, it is impossible foi many individuals to receive notice and demand on Form 17 and make payment of the taxes assessed thereon so that such taxes can be received by the collector within the ten-day period following June fifteenth, or within the ten-day period following the service of notice. You are requested therefore to enter on Form 17, as the date on which such assessed tax becomes due and payable, as near as possible, a date ten days subsequent to the time that said notice should be received in the ordinary course of the mails by the taxpayer, and where it appears that the full amount of tax assessed was placed in the mails within the ten-day period after the receipt of Form 17, or in case notice so sent is not delivered in due time by reason of delay in the mail and satisfactory evidence of that fact is furnished the penalty and interest in such cases will not be collected. This ruling applies to excess profits taxes as well as to income taxes. Where the office of a corporation, joint stock company, association or insurance company to which the collector ad- dresses the notice and demand for income taxes or income and excess profits taxes is situated so far from the collector's office that normal conditions render it impossible for pay- ment to reach the collector within ten days of the mailing of notice and demand, the procedure herein outlined with respect to individuals will govern with respect to corporations, joint stock companies, associations and insurance companies. Except as herein indicated the five per cent penalty will be imposed where there is a failure of the tax payment to reach the collector within ten days of the day of mailing by the collector of the notice and demand. Treasury Decision 2028 is hereby repealed. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: March 23, 1918. WM. G. McADOO, Secretary of the Treasury. (T. D. 2683.) Application of Articles 18, 23 and 24 of Regulations No. 41. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue, Revenue Agents and Others Concerned : 1. Article 18 of Regulations No. 41 (which provides for a constructive capital for the purpose of applying the graduated rates prescribed by Section 201 of the Act of October 3, 1917, in cases in which the deduction is determined under Section 210) applies only to cases in which the Secretary of the Treas- ury is unable satisfactorily to determine the invested capital for the taxable year (including cases arising under Article 62 of Regulations No. 41). If the deduction is so determined only upon the ground that the Secretary of the Treasury is unable satisfactorily to deter- 1228 mine the amount of invested capital for the pre-war period, but the invested capital for the taxable year can be satisfac- torily determined, the graduated rates prescribed by Section 201 will be applied upon the basis of such actual invested capital for the taxable year and not upon the basis of a con- structive capital. 2. If neither the income nor the invested capital for the pre-war period can be satisfactorily determined by the Secre- tary of the Treasury, the deduction will be computed under Section 205 (Article 23 of Regulations No. 41) if the invested capital for the taxable year can be satisfactorily determined, but if such invested capital for the taxable year cannot be satisfactorily determined the deduction will be computed as provided by Section 210 (Article 24 of Regulations No. 41). DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: March 26, 1918. W. G. McADOO, Secretary of the Treasury. (T. D. 2686.) Corporation Excise Tax— Decision of Court — 1. Gross Income. A corporation which did a brokerage business and bought securities for its customers, who paid only a part of the purchase price, paying interest on balances, the corporation also paying for the securities purchased only part of the purchase price and owing balances on which it paid interest, including in return of gross income the difference between the interest received and the interest paid, made incorrect return. 2. Interest. The interest received by plaintiff from its customers should be included in gross income. In determining net in- come, interest can be deducted only to an amount not exceeding the paid-up capital stock outstanding at the close of the year. 3. Judgment affirmed. The judgment of the United States District Court (246 Fed., 270; T. D. 2441) is affirmed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Circuit Court of Appeals, in the case of Altheimer and Rawlings Invesraent Company v. Allen, collector, is published for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved April 1, 1918: W. G. McADOO, Secretary of the Treasury. 1229 United States Circuit Court of Appeals, Elgrhth Circuit. 4918. December term, 1917. In error to the District Court of the United States for the Eastern District of Missouri. Altheimer and Rawlings Investment Company, plaintiff in error, v. B. B. Allen, United States Collector of In- ternal Revenue for the First District of Missouri, defendant in error. Before Hook and Smith, Circuit Judges, and Trieber, District Judge. Hook, Circuit Judge, delivered the opinion of the court: This is an action by the Investment company to recover from the collector of internal revenue an alleged excess of taxes assessed for the years 1909, 1910 and 1911 under the corporation tax act of August 5, 1909 (36 Stat., 11, sec. 38), and paid under protest. The trial court decided against the plaintiff. The facts were stipulated. The plaintiff is a Missouri corporation engaged in a stock and bond brokerage busi- ness, with a paid-up capital of $300,000. The tax imposed by the statute was an annual excise tax equivalent to 1 per cent upon the entire net income of the corporation in excess of $5,000 received by it from all sources durinjf the year. See Anderson v. Forty-two Broadway Co. (2^ U. S., 60). The statute provides that the net income shall be ascertained by deducting from the gross income from all sources (1) expenses, (2) losses, and (3) Interest ac- tually paid on indebtedness not exceeding the amount of paid-up capital outstanding at the close of the year. The controversy is over the deduction under the third clause for interest paid on indebtedness. The stipulation recites that plaintiff's business consisted In part of the purchase for customers of bonds and other securities which it carried for them on margin or part payment. It charged and received from them interest on the unpaid balances. In buying the securities for its cus- tomers plaintiff itself paid but part of the price "on said purchases" and paid interest on the balances it owed. In these transactions the interest received by plaintiff from its customers exceeded the interest it paid. In making its tax returns plaintiff deducted from the interest it received the entire amount of the interest it paid and listed the balance as gross income. The Commissioner of Internal Revenue in reforming the returns listed all interest re- ceived as gross income and limited the amount of deduc- tion for interest paid according to the statutory restric- tion in respect of the amount of plaintiff's capital stock. The plaintiff contends that when it borrowed money to carry the securities for its customers the indebtedness it incurred was theirs and that the interest it received from them on their own unpaid balances was, so far as re- quired, paid for them on such indebtedness. In other words, it is urged in effect that plaintiff was a mere con- duit for the transmission of sufficient of the interest re- ceived from Its customers to discharge the Interest accru- ing on the sums it borrowed, and hence only the excess remaining in its hands was Income. It is recited In the stipulation that plaintiff owed and paid interest on part of the purchase price "on said purchases" so carried by it for its customers. The recital is ingeniously framed, but it does not justify the assumption that plaintiff's extensive business was conducted otherwise than accord- ing to the familiar customs of stock and bond brokers. The suggestion upon which plaintiff's contention rests that it bought the stocks and bonds on time and that the sellers extended credit to plaintiff as agent for its cus- tomers and received interest from them indirectly is quite Inadmissible. In the usual course of the business which It should be assumed the plaintiff followed, the seller of securities Is paid in full by the broker and is not there- after Interested in the relation between the latter and his customer. Doubtless if the broker's capital is insufficient to carry his customers he borrows money from time to time for the purpose, and in that sense he may be said to borrow "on the purchases." But the borrowing is from any available financial source and is not for the customer personally but is In the broker's own behalf. A recog- nized source of profit to the broker is In the difference between the interest rate he charges his customers and 31330 that which he pays on moneys borrowed to carry them. He deals In debits and credits for a profit. The borrowing by the broker supplements the capital employed in his business, and in the case of a corporation subject to the excise tax the deduction from gross income for interest paid on its indebtedness is limited to interest on an amount of indebtedness not exceeding its paid-up capital stock outstanding at the close of the year. In this par- ticular the plaintiff's borrowing to carry its customers was not unlike that of a mercantile corporation whose capital is insufficient for the volume of its business. It should be noted that this case arose before the amend- ment of October 3, 1913 (38 Stat., 166. Sec. II., G. b). The judgment is affirmed. (T. D. 2687.) Providing for the Transmittal of Ownership Certificates in Which Exemption is Claimed by Means of Information Return, Form 1096. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and others concerned: Where a debtor corporation, or its duly authorized withhold- ing agent, has made no payments of interest to nonresident alien individuals, or foreign corporations, having no office or place of business in the United States, or has withheld no tax from citizens or residents of the United States, whether or not the bonds upon which such interest accrued contain a tax-free covenant clause, the exemption certificates filed in connection with such interest payments, shall not hereafter be forwarded to Collectors of Internal Revenue, accompanied by a return on Form 1012, Revised, but shall be transmtited direct to the Com- missioner of Internal Revenue (Sorting Division), Washington, D. C, accompanied by a return on Form 1096. When used in this connection. Form 1096 shall be filed monthly, and in such cases, this office will not require that the return be sworn to. The number of exemption certificates thus transmitted, and the total amount of interest paid shall be entered on line 1 of the return. In all cases, however, where a debtor corporation or its duly authorized withholding agent has withheld the tax and is there- fore required to render a return on Form 1013, Revised, all certificates received shall be accounted for on such monthly leturn, as directed by the instructions thereon. All instructions issued by this office in conflict herewith, are hereby superseded and repealed. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 1, 1918. W. G. McADOO, Secretary of the Treasury. 1231 (T. D. 2688.) Procedure under which Collectors are authorized to refund excessive payments of Internal Revenue tax — Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue: Beginning April 1, 1918, there will be advanced to each Col- lector of Internal Revenue, at the beginning of each quarter of the fiscal year, out of the appropriation for the refundment of internal revenue taxes, a sum estimated to be sufficient for the repayment to taxpayers of certain excessive collections, as follows : 1. Collections exceeding the tax shown by the return of the taxpayer to be due. 2. Collections exceeding the amount of tax shown by the assessment list to be due. 3. Duplicate payments where: (a) Both are made in advance of assessment; (b) Both are made after assessment; (c) One is made before, and one after assessment. 1. Procedure where a collection has exceeded the tax shown in the taxpayer's return as due. The Collector will enter on the assessment list the full amount paid, and in the ''Remarks" column of the list will note the amount of the excess. The complete data regarding the excessive collection Is then to be entered on the schedule of Claims for Authority to Re- fund, Form 751. The "Paid," "Due," and "Refundable Ex- cess" columns on the Form will be totaled. Form 751 is to be made in triplicate, one copy to be retained by the Collector, and two to be forwarded securely attached to the proper assessment list. A single Form 751 cannot be used for items on lists of the separate classes. In the Provirg Division of the Bureau the amount shown on Form 751 as due will be checked against the taxpayer's return, and the amount shown on the assessment list as paid will be checked against the similar item on Form 751. The original Form 751 will remain attached to the assess- ment list and will form an integral part thereof, so that the Commissioner's signature of approval of the assessment list will be, to the Collector, sufficient evidence of the Commis- sioner's approval of the claim. To effectuate this, there should be typewritten on the first page of Form 1110, below the line reading, "Total Chargeable to Collector," the words, "Amount Refundable on Form 751." Upon receipt of the returned claim, thus determined as approved by the Commissioner, the Collector will immediately make refund to the taxpayer, clearly designating upon the draft the nature of the refund, as, for instance, "Refund under claim on Form 751, March list, 1918." The list to be designated is the list on which the claim was approved, rather than the list on which the assessed or overpayment was leported. 1332 2. Procedure where a collection has exceeded the tax. The procedure will be identical with that outlined under subheading (1), above, except that in the "Remarks" column on the assessment list the exact amount paid is to be noted. 3. Procedure where a tax has been paid wholly or in part in duplicate. (a) Where both payments are in advance, there shall be en- tered on Form 751 a notation showing both lines of the ad- vance payment list or lists on which payments appear. If the amounts of the two payments differ, the Collector shall claim aiithority for refund of the lesser payment. (b) Where the assessment has been made, entries will be m.ade on the assessment list to show both dates of payment. A similar notation should be made under the item claimed on Form 751 as refundable. The total amount collected is to be reported on Forms 325 and 51-B. (c) Where one payment has been made before and one after the entry of assessment, notations will be made on Form 751 showing the line of the list on which the advance payment was reported and the line on which the assessment was entered. Except as indicated, the balance of procedure under sub- heading (3) will correspond to the procedure fully outlined under subheading (1). DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 1, 1918. W. G. McADOO, Secretary of the Treasury. (T. D. 2689.) Computation of Excess-Profits Tax for a Period of Less Than a Full Year (Supplementing Article 20 of Regulations No. 41); Filing of Excess-Profits Tax Return for Such a Period (Supplementing Articles 10, 11 and 12 of Regula- tions Wo. 41). Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue, Revenue Agents, and Others Concerned : 1. If a taxpayer who is engaged in a trade or business the Article 43 of Regulations No. 41 provides that the average in- net income from which is subject to taxation at the graduated rates imposed by Section 201 of the Act of October 3, 1917, makes a return for a period of less than twelve months, vested capital shall be determined by monthly average based upon the number ^f months in the period, and Article 20 pro- vides that the deduction will be an amount which bears the same ratio to the deduction allowable for a full year as the number of months in such period bears to twelve months. In applying the rates of tax, however, the invested capital used will be an amount which bears the same ratio to such full 1333 average invested capital as the number of months in the period for which the return is made bears to twelve months. ILLUSTRATION: — A corporation makin-g its return on a calendar year basis started business August 16, 1917, with a capital of $100,000. which remained unchanged for . the balance of the year 1917. Its net Income for that period was $8,000. . . . ., , The deduction computed under the provisions of Articles 20 and 21 would, as this corporation was not in existence during the whole of at least one calendar year during the pre-war period, be 8 per cent of the invested capital, or $8,000, plus $3,000, a total of $11,000. But, inasmuch as the return is being made only for a period of four and one- half months, the deduction would be reduced to an amount which bears the same ratio to $11,000 as four and one- half months bears to a full year of twelve months, or, in other words, the deduction would be reduced to $4,125. For the purpose of applying the rates of taxation the invested capital of $100,000 would likewise be reduced to an amount which bears the same ratio to the full invested capital as the number of months in the period for which the return is made bears to twelve months, or, in other words, would be reduced to $37,500. The amount of the net income taxable at each rate would be as follows: In excess of the deduction and not in excess of 15 per cent of the capital (rate 20%) $1,500.00 In excess of 15 per cent of the capital and not in excess of 20 per cent thereof (rate 25%) 1,875.00 In excess of 20 per cent of the capital and not in excess of 25 per cent thereof (rate 35%) 500.00 The Tax would then be computed as follows: 20% of $1,500 $300.00 25% of $1,875 468.75 35% of $500 175.00 Total tax $943.75 The same result would be reached by computing both the deduction and the tax on the basis of an invested capital averaged over twelve months (that is, by dividing the sum of the average capital for each month by twelve instead of by four and one-half, the number of months in the period), and by reducing the specific deduction to an amount which bears the same ratio to $3,000 as the number of months in the period bears to twelve months. Thus, in this case, the invested capital upon this basis would be $37,500, 8% of which would be $3,000, to which would be added four and one-half twelfths of the $3,000 specific deduction, making a total deduction of $4,125, the • same result as reached by the method used in the illus- tration. 2. If a taxpayer who is engaged in a trade or business the net income from which is subject to taxation at the rate of 8 per cent imposed by Section 209 of the Act of October 3, 1917, makes a return for a period of less than twelve months, the deduction of $3,000 or $6,000 allowed under that section will be reduced to an amount which bears the same ratio to such full deduction as the number of months in the period bears to twelve months. ILLUSTRATION :— A Corporation engaged in the busi- ness of real estate agents taxable under Section 209 of the Excess Profits Tax Law has, up to and Including the year 1916. made its income tax returns upon a calendar year basis. It has since given notice, however, in accordance with the provisions of the Income Tax Regulations (article 211) and changed to the basis of a fiscal year ending April 30th. As a result its first excess-profits tax return would be made for a period of four months ending April 30, 1917. Its net income for such period was $25,000. In com- puting the excess-profits tax upon this amount, however, the deduction of $3,000 would be allowed to it for a full year would be reduced to an amount which bears the same ratio to $3,000 as the number of months for which the re- 1234 turn Is made bears to twelve months; In other words, It would be reduced to $1,000. The excess-profits tax in this case would be 8 per cent on the amount of net income in excess of $1,000; in other words, 8 per cent of $24,000, or $1,920. 3. The above rulings apply only in the case of a taxpayer who (because of having just established a fiscal year or of having just organized or engaged in business, or for other like reasons) is entitled to make a return for a period of less than a full year, and are not to be construed as authorizing a cor- poration or partnership which has already established a fiscal year ending in 1917, but part of which falls within 1916 to compute its tax in any other manner than as prescribed in Article 19 of Regulations No. 41. 4. A domestic corporation or partnership or a citizen or resident of the United States, entitled to make a return for a period of less than a full year, will be required to make such return if the net income for such period is at the rate of $3,000 per year or more in the case of a corporation, or of $6,000 per year or more in the case of a partnership or individual. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 1, 1918. W. G. McADOO, Secretary of the Treasury. (T. D. 2691.) Returns on Form 706 for the estates of nonresident decedents to be forwarded direct to the Commissioner of Internal Revenue for transmittal to the Collector. Treasury Department, Office of the Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: Hereafter returns on Form 706 for the estates of nonresi- dent decedents shall be forwarded (in duplicate) by the executor direct to the Commissioner of Internal Revenue, Treasury Department, Washington, D. C, who will, after reviewing the returns, transmit them to the proper Collector. The date on which the return is received by the Commissioner of Internal Revenue will be considered the date of original filing with the Collector for the purpose of determining whether the return is filed within the period prescribed by law. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 8, 1918. L. S. ROWE, Acting Secretary of the Treasury. 1235 (T. D. 2692.) Heads of familities and married men with wives living with them include only persons whose families or wives actually reside with them. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: Section 7 of the Income Tax Act of September 8, 1916, as amended by the Act of October 3, 1917, provides that for the purpose of the normal tax only there shall be allowed as an exemption in the nature of a deduction from the amount of the net income of each citizen or resident of the United States the sum of $3,000, plus $1,000 additional if the person making the return be a head of a family or a married man or woman with a wife or husband living with him or her, except that only one deduction of $4,000 shall be made from the aggregate income of both husband and wife when living together, and plus $200 additional, if the person making the return be the head of a family, for each child dependent upon such person if under eighteen years of age or if incapable of self-support because mentally or physically defective. Section 3 of the War Income Tax Act of October 3, 1917, provides that in the case of the tax imposed by the later Act the exemptions of $3,000 and $4,000 provided in Section 7 of the former Act shall be respectively $1,000 and $2,000. Paragraph 153 of the Income Tax Regulations provides: "A head of a family is a person who actually sup- ports and maintains one or more individuals who are closely connected with him by blood relationship, relationship by marriage, or by adoption, and whose right to exercise family control and provide for these dependent individuals is based upon some moral or legal obligation.'* Applying only to citizens and residents of the United States, there is accordingly an individual exemption of $3,000, except that if husband and wife live together a joint exemption of $4,000 under the earlier Act and $2,000 under the later Act is substituted for the several exemption of $3,000 each under the earlier Act and $1,000 each under the later Act, and that if the taxpayer be a head of a family, consisting of a person or persons other than a wife or husband alone, his exemption is $4,000 under the earlier Act and $2,000 under the later Act, plus $200 for each dependent child. In the case of a married man or married woman, the joint exemption replaces the individual exemptions only if his wife lives with him or her husband lives with her. In the absence of continuous actual residence together, whether or not a man or woman has a wife or husband living with him or her within the meaning of the statute must depend on the character of the separation. If merely occasionally and temporarily a wife is away on a visit or a husband is away on business, the joint home being maintained, the additional exemption applies. The unavoidable absence of a wire or husband at a sanatorium or asylum on account of illness does not preclude claiming the exemption. If, however, the husband voluntarily and continu- ously makes his home at one place and the wife hers at 1236 another, they are not living together for the purpose of the statute, irrespective of their personal relations. A head of a family is a person who actually supports and maintains one or more of the individuals described in para- graph 153 of the Regulations in one household. In the absence of continuous actual residence together, whether or not a person with dependents is a head of a family within the meaning of the statute must depend on the character of the separation. If a child or other dependent is away only tem- porarily at school or on a visit, the common home being still maintained, the additional exemption applies. If, however, the dependent continuously makes his home elsewhere, his benefactor is not the head of a family, irrespective of the question of support. Resident aliens claiming exemption because of families or wives residing abroad are not heads of families or married men or women with wives or husbands living with them within the meaning of the statute, and they are in no case entitled to more than their individual exemptions of $3,000 under the earlier Act and $1,000 under the later Act. DANIEL C. ROPER, Commissioner of Internal Revenue, Approved April 8, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2693.) Proof necessary to be filed by certain organizations to establish the fact that they are exempt from filing income tax returns or paying an income tax. Treasury Department, Office of the Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: The exemption from filing returns and paying income tax of corporations or associations organized and operated ex- clusively for religious, charitable, scientific or educational purposes, business leagues, chambers of commerce, boards of trade, civic leagues, cemetery companies, and pleasure and recreation clubs, under the Act of September 8, 1916, as amended by the Act of October 3, 1917, is conditional. In order to establish exemption and thus be relieved of the duty of filing returns and paying income tax, it is necessary that such organizations as are specified hereinbefore file an affidavit with the Collector of Internal Revenue of the District in which they are located, which will show the character of the organization, the purpose for which organized, the source of income and disposition of the same, and whether or not any of its income is credited to surplus or inures or may inure to the benefit of any private stockholder or individual. To such affidavit should be attached a copy of the charter or articles of incorporation and by-laws of the organization. Upon receipt of the affidavit accompanied by the copies of the charter, or articles of incorporation and copy of the by- laws by the Collector he will advise the organization whether 1237 or not it is exempt. If, however, the Collector is in doubt as to the taxable status of the organization he will refer the affidavit and accompanying papers to the Commissioner of Internal Revenue for decision. If it is held that the corporation itself is exempt from the income and excess profits taxes, it is not, however, exempt from the withholding requirements nor from furnishing in- formation in accordance with the provisions of the Act of October 3, 1917. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 8, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2695.) Amending Treasury Decision 2622, relative to advance payments of income and excess profits tax. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: Treasury Decision 2622, dated December 26, 1917, is amended by the revocation of the following paragraph: "The interest at the rate of 3 per cent per annum (365 days), allowed to a taxpayer on advance payments on income and excess profits taxes, must be considered income and accounted for as income by the taxpayer in his return for the year in which said interest is allowed." DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 11, 1918. W. G. McADOO, Secretary of the Treasury. (T. D. 2696.) Treatment for taxation purposes of amounts ostensibly paid as compensation for services of officers and employes of business enterprises. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: Section 5(a) of the Income Tax Act of September 8, 1916, as amended, provides, as to the income of individuals and partnerships, that for the purpose of the tax there shall be allowed as deductions, among others, "the necessary expenses actually paid in carrying on any business or trade," and Sec- tion 12(a) provides that the net income of a corporation shall 1238 be ascertained by deducting from the gross amount of its in- come received within tlie year, among other tilings, "all the ordinary and necessary expenses paid within the year in the maintenance and operation of its business and properties." Payments for. services by business enterprises (including individuals in business, partnerships and corporations may oi course be deducted under this general language. The Govern- ment, entitled to taxes based on the net income of each enter- prise, is interested and authorized, however, to see that each specific expenditure sought to be deducted is in itself "neces- sary." The question is by what examination and what test this shall be determined. The subject is not dealt with in any general way in the Income Tax Regulations, although Article 138 bears on special payments to employes of cor- porations. The test of deductibility in the case of compensation pay- ments is whether they are in fact payments purely for services or include some other element. But in the case of any com- pensation, however determined, which exceeds amounts ordi- narily paid for like services in like enterprises under like cir- cumstances, the burden is upon the enterprise to show that the amount paid was solely the purchase price of services. This test and its practical application may be further stated and illustrated as follows: 1. Any amount paid in the form of compensation, but not in fact as the purchase price of services, is not deductible. (a) An ostensible salary may be a distribution of a divi- dend on stock. This is likely to occur in the case of a cor- poration having few stockholders, practically all of whom draw salaries. If in such a case the salaries are based upon or bear a close relationship to the stockholdings of the officers or employes, it would seem likely that the salaries, if in excess of those ordinarily paid for similar services, are not paid wholly for services rendered, but in part as a distribu- tion of earnings upon the stock. (b) An ostensible salary paid by a corporation may be in part a waste or appropriation of assets of the corporation. This may occur where salaried employes are in control of the corporation through holding directly or indirectly a majority of its stock or, in the case of a large corporation with many stockholders, o\^Tiing a substantial minority of its stock, and the tendency of the officers unduly to inflate their salaries must be taken into account. If a compensation contract with the majority stockholder or stockholders is approved by all the stockholders as well as by the directors, it might, how- ever, be dealt with like any other contract. (c) An ostensible salary may be in part payment for prop- erty. This may occur, for example, where a partnership sells out to a corporation, the former partners agreeing to con- tinue in the service of the corporation. In such a case it may be found that the salaries of the former partners are not merely for services, but in part constitute payment for the transfer of their business. 2. The form or method of fixing compensation is not de- cisive as to deductiblity. While any form of contingent compensation invites scrutiny as a possible distribution of earnings of the enterprise, it does not follow that payments on a contingent basis are to be treated fundamentally on any basis different from that apply- ing to compensation at a flat rate. Generally speaking, if 1239 contingent compensation is paid pursuant to a free bargain between the enterprise and the individual made before the services are rendered, not influenced by any consideration on the part of the employer other than that of securing on fair and advantageous terms the services of the individual, it should be allowed as a deduction even though in the actual working out of the contract it may prove to be greater than the amount which would ordinarily be paid. 3. As to compensation determined after services have been rendered, reasonableness is ordinarily the controlling test of deductibility. In certain instances apparently of this sort it may be shown that the compensation is fixed according to a custom or practice having virtually the force of a contract. Where, however, such is not the case and it is for the management to fix compensation such as is deemed fair, it is just to assume that true compensation is only such amoimt as would ordinarily be paid in like circumstances by -other similar enter- prises. 4. In connection with the questions discussed above, the fol- lowing rulings as to the treatment of amounts ostensibly paid as compensation, but not allowed to be deducted as such, appear to be warranted. (a) In the case of excessive payments by corporations, if such payments correspond to or bear a close relationship to stockholdings, the amount of the excess should be treated as dividends and would thus be exempt from the normal tax and from the excess profits tax in the hands of the recipients; or if such payments represent an appropriation of assets of the corporation by officers who control it and fix their com- pensation in violation of the rights of the corporation, the amount of the excess, while disallowed as a deduction by the corporation, should be treated as compensation of the in- dividuals subject to the normal and the excess profits taxes, compensation illegally secured being none the less subject to tax in all respects; or if such payments constitute in part payment for property, the amount of the excess should be treated by the corporation as a capital expenditure and by the rtcipient as part of the purchase price. (b) In the case of excessive payments by individuals or partnerships, the amounts disallowed should ordinarily be treated as partnership shares and would thus be free from the excess profits tax to the recipient, but, of course, still subject to the income tax, except that payments for property should be treated by the individual or partnership as a capital expenditure and by the recipient as part of the purchase price. The foregoing rules naturally do not permit a ready deter- mination of every question arising as to compensation pay- ments, but applied in the light of full knowledge of the facts In the particular case they do, however, indicate a basis of solution. They may be smnmed up as follows: Compensation on whatever basis fixed, representing only the price paid for services pursuant to a fair bargain made in advance between the individual and tjtie business enterprise, is deductible in determing the taxable net income of the enter- prise. Payments nominally as compensation for services, which in fact include amounts paid as dividends, waste of corporate assets, payments for property or for anything other than services, are deductible only to an amount not in excess of compensation for like services in similar enterprises. 1240 Compensation greater than that ordinarily paid for like service* in similar enterprises must be shown to represent payment for services only. In the case of compensation fixed after services are rendered and not in accordance with any contract or any custom or practice amounting virtually to a contract, reasonableness is ordinarily the controlling test of deductibility. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 10, 1918, R. C. LEFFINGWELL, Acting Secretary of the Treasury. (T. D. 2697.) Suit for Recovery of Taxes by the Government — United States Circuit Court of Appeals, Sixth District. United 'States, plaintiff in error, vs. Nashville, Chattanooga and St. Louis Railway, defendant in error. Error to' the District Court of the United States for the Middle District of Tennessee. (Decided April 3, 1918.) Treasury Department, Office of Commissioner of Internal Reevnue, Washington, D. C. The appended decision of the United States Circuit Court of Appeals for the Sixth Circuit, in the case of the United States V. Nashville, Chattanooga and St. Louis Railway, is published for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved April 16, 1918: J. H. MOYLE, Acting Secretary of the Treasury. 1. False or Incorrect Returns. — The w^ord "false," as used in the fifth subdivision of Section 38, of the Act of August 5, 4.909, providing that in case of any return made with false or fraudulent intent the Commissioner of Internal Revenue shall add 100 per centum of the tax, means "untrue" or "incorrect," and does not necessarily mean intentionally or fraudulently false. 2. Common-Law Action of Debt for Taxes. — A common-law action of debt lies in favor of the Government whenever by accident, mistake, or fraud, taxes have not been paid; thus the Government may recover a personal judgment for a tax whenever there exists a duty to pay, provided another remedy has not been made exclusive by clear and specific declaration. 3. Reassessment as Prerequisite to Suit. — Act of August 5, 1909, Section 38, does not make the remedy by way of a re- assessment by the Commissioner of Internal Revenue exclusive of all other remedies for collection of excise tax imposed on corporations, and suit may be brought under Revised Statutes, 1241 Section 3213, providing that taxes may be sued for and re- covered in the name of the United States, in any proper form of action, before any Circuit or District Court of the United States for the district within which liability to such tax is incurred, or where the party from whom such tax is due resides at the time of the commencement of the action, with- out any such reassessment. 4. Operating Expenses and Depreciation. — Though what is a necessary expense of operation and what is a reasonable al- lowance for property depreciation are ultimately questions of fact, so far as they involve legal questions they are absolutely judicial questions, and the declaration in a suit to recover excise tax imposed on corporations by the Act of August 5, 1909, which fails to show the making of a new assessment by the Commissioner of Internal Revenue, is therefore not de- murrable. 5. Declaration in Suit to Recover Tax— Evidence.— Evidence sustaining allegations of incorrectness in returns by corpora- tion subject to excise tax imposed by Act of August 5, 1909, need not be set out in the declaration in a suit to recover such tax; declaration here sufficiently averred erroneous or untrue return of operating expenses and deductions for de- preciation. 6. Declaration in Suit to Recover Tax— Bill of Particulars. — Where declaration in action to recover of a corporation the excise tax imposed by Act of August 5, 1909, expressly avers that alleged deductions were not reasonable allowances for depreciation within the meaning of such act, if more definite or detailed information is needed to enable defendant to plead or prepare for trial, remedy is by bill of particulars. 7. Judgment Reversed. — Judgment of the District Court is reversed. [DECISION OF COURT.] (November 7, 1917.) Northwestern Mutual Life Insurance Company v. Fink, collector. (District Court, E. D. Wisconsin.) (248 Fed., 568.) Recovery of excess taxes paid on erroneous second assessment. Section 3225, Revised Statutes. (Extracted from Judge Geiger's opinion in the above case In which judgment was rendered for plaintiff.) A final question, one not suggested in the pleadings, briefly referred to in oral arguments, but later elaborately discussed in briefs, arises on these facts: In making its return for the year 1910, plaintiff omitted an item of $77,000 from the income side. It is an aggregate of receipts from agencies, omitted because information respecting the accounts to which individual items were distributable was not at hand at the time of making the return, and, apparently, was in good faith treated as a "suspense" item which would naturally, upon later ascertainment, go into the return for the ensuing year. There is no suggestion that the facts are not consisteiit with perfect good faith. The record attests fully that the omission, if it involved delinquency at all, arose as stated— it was an erroneous failure to include the items. 1242 The Government urges that such failure bars the right to maintain the action, and bases its contention upon Section 3225, R. S. U. S. (Comp. St. 1916, Sec. 5948), which is as- serted to be incorporated into the excise law in question: "When a second assessment is made in case of any list, statement, or return, which in the opinion of the collector or any deputy collector was false or fraudulent, or contained any understatement or undervaluation, no tax collected under such assessment shall be recovered by any suit unless it is proved that the said list, statement, or return was not false nor fraudulent, and did not contain any understatement or under- valuation." The broad proposition is that any and every error of under- statement or undervaluation, howsoever innocently made, bars relief against a reassessment, howsoever inaccurate, or unjust it may be. It may be said confidently that so drastic a rule should not be accepted unless unmistakably clear language, disclosing a legislative purpose and intent viewed in the light of history and results to be achieved, leaves no alternative. I shall assume that Section 3225 is brought into the tax law in question; and it necessitates consideration of that section as part of a chapter, dealing generally with practice, procedure, rights and remedies awarded to both Government and taxpayer or citizen, in the matter of assessment, collec- tion, remission and refund of public dues. These laws are not of recent enactment. The times and conditions at and under which they came into being to further the raising of revenue to meet a situation of great national stress, the administra- tive recognition and application accorded them for over fifty years, may safely aid in throwing light upon the just inter- pretation to be given. Without narrating historically the ad- vent and amendment of this particular Section 3225 and allied provisos, it suffices to say that they had their begin- nings in the Civil War Revenue Act of June 30, 1864 (13 U. S. Stat., p. 223, c. 173), as amended by the Act of July 13, 1866 (14 U. S., Stat., 98, c. 184). They exhibit the early recognition by the Government of the necessity of ways and means for revising, both in the interest of the Government and the taxpayer, the returns or assessments made or levied, and for refunding or recovery of taxes actually paid; and from the earliest occasions when interpretation of these stat- utes was called for the courts here have uniformly given to the results accomplished by legislation on the general subject, this broad characterization: "The revenue measures of every civilized government consti- tute a system which provides for its enforcement by officers commissioned for that purpose. In this country, the system for each State, or for the Federal Government, provides safe- guards of its own against mistake, injustice, or oppression, in the administration of its revenue laws. Such appeals are al- lowed to specified tribunals as the lawmakers deem expedient. Such remedies also for recovering back taxes illegally exacted as may seem wise are provided. In these respects the United States have, as was said by the court in Nichols v. United States, 7 Wall., 122 (19 L. Ed. 125), enacted a system of corrective justice, as well as a system of taxation in both its customs and internal revenue branches. That system is intended to be complete. * * * So also in the internal revenue department, the statute allows appeals to the asses- sor to the Commissioner of Internal Revenue; and, if dis- satisfied with his decision, on paying the tax the party can 1243 •lie the collector; and if the money was wrongfully exacted, the courts will give him relief by a judgment, which the United States pledges herself to pay," Per Miller, Justice, Cheatham v. U. S., 92 U. S. 88, 23 L. Ed. 561. A careful reading of adjudicated cases — indeed, all legisla- tion upon the varied phases of public revenues — suggests that at no time has there been a purpose to cut off or to impair, either as against the Government or the citizen, this "system of corrective justice" attending the administration of revenue laws. At the outset, the proposition advanced by the defence is repugnant, utterly, to this view, and the broad purpose dis- closed. If it is not obviously, it is easily demonstrably so. A few considerations of a practical nature — which a court may entertain — will be helpful. When property is assessed for taxation upon an ad valorem basis, the taxing officers frequently must, initially, determine values. Even in such cases the taxpayer is not left wholly remediless to review or revise the finding of the assessing or taxing officer. In very rare situations is it possible justly to ascribe to any individual whether he be the interested taxpayer or the public assessor, the power or the duty to make an initial valuation to be accepted by the one adversely interested as indubitably fair; and, as indicated, there have arisen of necessity in the interest of just dealing the varying methods of revision and correc- tion. Coming to the particular case before us, where assess- ments are based upon retiims exhibiting great magnitude and complexity of business operations, the possibility and the probability of errors — without a suggestion of attendant bad faith — is increasingly present. It may safely be said that the great majority of returns under these excise and income tax laws contain items involving for their fixing and determi- nation, judgment, honestly and conscientiously exercised; and it is equally true that, no matter how conscientiously one man may fix and determine an item, another, with equal probity and integrity/ may fix it at a substantially higher or lower figure. The very purpose is to enable revision, to cor- rect the mistake, of omission, or commission, or to prevent frauds; and it would be anomalous to assume infallibility on the part of the Government in its efforts at revision, where- fore mistakes of the citizens only are to be corrected. Tliis is said because, in my judgment, the drastic construction of Section 3225 now insisted upon will, if adopted, lead to that result as a matter of practical administration and application. It means that the taxpayer cannot prevail imless he succeeds in reinstating his own return, item for item, against the revision or reassessment. Naturally suits to recover can rarely be brought when the reassessment is more favorable than the original return, though even such result can con- ceivably come through an entire rearrangement of the return through the exclusion of items admitted and the inclusion of items contested by the taxpayer. But this is true as a prac- tical matter: Every reassessment which results in an in- creased tax must involve expressly or by necessary implica- tion the opinion or conviction of the i^eviewing officer that the original return contained, somewhere or somehow, an under- statement or undervaluation, a false (erroneous, or fraudu- lent) item or items. Therefore unless the taxpayer can es- tablish that his original return was right, and hence that the reassessment, in its attempted revision or additions, is wrong, in every particular, he must fail in his action. If this is pos- 1244 sible, and it must follow so strict an interpretation of the statute (Section 3225), then there is little left that can com- mend itself — to the citizen or taxpayer — of any so-called sys- tem of "corrective justice." The present case furnishes a good illustration: Assuming that the exaction of 1 per cent on the millions of dividends treated as income is illegal and unjust, a remedy would have to be denied because of an honest error respecting an item, by comparison, trifling. I am unwilling to give to the section in question any such interpretation; and no matter how drastic an application may be compelled in cases of actual fraud — whether the items fraudulently withhold or misstated be large or small — the view that the section aims to furnish a rule of proof, to give to the finding of executive officers a status or dignity prima facie good, to cast upon the citizen the burden of overthrowing it, thereby giving the section a distinct place and function in the corrective and revisory "system" of the revenue laws, is far more reasonable and commendable. It furthers the accomplishment, by the Government or by the taxpayer, of the general purpose of enabling just revision or •ecovery; whereas, the view urged by the defendant makes he statute highly penal, and, in its application, one-sided, •esulting, as indicated, in foreclosure of recovery in every case Adhere the original return cannot be established, item for item, n opposition to the Government revision. (T. D. Authorizing collectors in certain cases of erroneous assessment to present blanket claims monthly on Form Wo. 47. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. 0. To Collectors of Internal Revenue: Hereafter collectors will present once a month a blanket claim on Form 47 for the abatement of taxes coming within the following classes of taxes erroneously assessed: 1. Duplicate assessments. 2. Cases where specific exemption has not been taken on the taxpayer's return and the assessment has ac- cordingly been excessive to the extent of the tax assessed bcause of failure to take exemption. 3. Cases of excessive assessment caused by mathemat- ically erroneous calculations of tax by the taxpayer upon his return. 4. Fifty per cent additional taxes where a tentative re- turn has been filed within the time required by law, but where the fact of such filing has been overlooked in the collector's oflace and an assessment of 50% additional tax has accordingly been made, and is unquestionably erroneous. In all other cases of 50% additional tax assessments, a claim must be presented by the taxpayer, as at present. In preparing these claims, the collector will paste upon the blank space on Form 47 a schedule showing the name and address of the taxpayers; the month, page, and line of the assessment list; amount assessed, amount due, amount abate- able; the nature of the erroneous assessment, as classified above; and a brief and clear statement of the ground for abatement. These claims should be forwarded so as to be received 1245 in the Commissioner's office by the 5th of each month, in order that tlie allowance may be scheduled on the Form 7220 for the same month. Where amounts abateable have been assessed upon lists of the different classes, separate claims must, of course, be presented, each to cover the items upon the list, or lists, of a given class. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 16, 1918. J. H. MOYLE, Acting Secretary of the Treasury. (T. D. 2700.) Additional tax on undistributed earnings of corporations — Sec- tion 10(b) and Section 31(b), Act of September 8, 1916, as amended; Investment of such earnings. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: ' Inquiries have been received from corporations confronted with liability to additional tax under Section 10(b) of the Act of September 8, 1916, as amended, upon undistributed net earnings of the previous taxable year, as to what restrictions apply to investment of such earnings in obligations of the United States issued after September 1, 1917. Section 10(b) added by Section 1206 of the Act of October 3, 1917, provides as follows: In addition to the Income tax imposed by subdivision (a) of this section, tliere shall be levied, assessed, collected, and paid annually an additional tax of 10 per centum upon the amount, remaining undistributed six months after the end of each calendar or fiscal year, of the total net In- come of every corporation, Joint-stock company or associa- tion, or insurance company, received during the year. • • • The tax imposed by this subdivision shall not apply to that portion of such undistributed net income which is actually Invested and employed in the business or is retained for employment in the reasonable requirements of the business or is invested in obligations of the United States issued after September first, nineteen hun- dred and seventeen. ♦ • • ." Section 31(b) added by Section 1211 of the Act of October 3, 1917, provides in part as follows: Any distribution made to the shareholders, or members of a corporation, Joint-stock company, or association, or insurance company. In the year nineteen hundred and sev- eteen, or subsequent tax years, shall be deemed to have been made from the most recently accumulated undi- vided profits or surplus." * * • The effect of this section is dealt with under Regulations No. 33 Revised, Article 107, in Treasury Decision 2659 and Treasury Decision 2678. Under these rulings the burden is upon the corporation seeking to establish a distribution in the current year of profits of the preceding taxable year to show that all the earnings of the current year have been first dis- tributed. 1246 In determining the source of earnings from which a particu- lar distribution is made a corporation is, however, permitted to treat the undivided profits and surplus of the current year as reduced by payments for income and excess profits taxes or if keeping its accounts upon an accrual basis by proper re- serves for such taxes, although such payments or reserves are not deductible in computing the income of the corporation for income and excess profits taxes. The restrictions as to the distribution of earnings of prev- ious taxable years resulting from the presumption that all current distributions are from current earnings do not apply to the use of earnings for investments by corporations. There is in the statutes no limitation or restriction as to the source from which may be taken earnings used for this purpose. Amounts invested in obligations of the United States issued after September 1, 1917, may thus be treated as made from such earnings as the corporation may designate. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 16, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2702.) Authorizing debtor corporations and withholding agents to accept, until June 1, 1918, certificates of ownership, on the old forms, when properly executed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: 1. This office has received since the issue of the revised forms of ownership certificates and monthly returns, a number of certificates and returns executed on the old forms. It appears that there is a misunderstanding among banks, col- lecting agents, debtor corporations and withholding agents as to whether the old forms of certificates may be used in lieu of the revised forms. 2. In view of the fact that the revised forms were placed at the disposal of the public over three months ago, this office is of the opinion that a reasonable period of time has elapsed in which to permit the public to have become familiar with them. In order, however, to prevent inconvenience to individ- uals and organizations required to use such forms, this office grants an extension of time until June 1, 1918, during which time OAvnership certificates, properly executed on the old forms, presented by individuals or organizations, either resident or foreign may be accepted by debtor corporations and withhold- ing agents. 3. On and after June 1, 1918, the use of the old forms of certificates will be discontinued in connection with coupons and interest orders, whether owned by citizens or residents, etc., of the United States, or non-resident alien individuals, firms, or foreign corporations. Banks and collecting agents, debtor corporations, and withholding agents shall refuse to 1247 accept the old forms after that date, and collectors of internal revenue hereafter receiving monthly returns accompanied by certificates on the old forms, when it shall appear that such certificates were filed with debtor corporations or withholding agents subsequent to June 1, 1918, shall require the debtor corporation or withholding agent concerned to file certificates on the revised forms, as herein provided. 4. Collectors are further advised that monthly returns ren- dered on the old forms are no longer acceptable to this office, and when so received cause a needless expenditure of time in auditing. All monthly returns reporting payments of interest on bonds, or payments of dividends on stock of domestic cor- porations registered in the name of foreign corporations, not having an ofiice or place of business in the United States, should be prepared on Form 1013, Revised (1918). 5. In order that the fulfillment of the requirements herein provided may cause as little hardship as possible to individ- uals, banks, collecting agents, corporations, etc., collectors should satisfy themselves that they have a sufficient supply of the revised forms on hand to meet anticipated demands, and where the supply is not deemed sufficient, requisition should be made without delay on Form 16, Revised, for such additional quantity as may be necessary. Collectors are re- quested to disseminate this information throughout their dis- tricts as quickly as possible. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 18, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2705.) United States Bonds bearing interest at a higher rate than four per centum to be accepted at par and accrued interest in payment of estate tax. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. April 23, 1918. To Internal Revenue Officers and Others Concerned: Section 14 of the Act of April 4, 1918 (Public— No. 120— 65th Congress), provided in part: "That any bonds of the United States bearing interest at a higher rate than four per centum (whether Issued under section one of this Act or upon conversion of bonds Issued under this Act or under said Act approved April twenty-fourth, nineteen hundred and seventeen), which have been owned by any person continuously for at least six months prior to the date of his death, and which upon such date constitute part of his estate, shall, under rules and regulations prescribed by the Secretary of the Treas- ury, be receivable by the United States at par and accrued interest in payment of any estate or inheritance taxes imposed by the United States, under or by virtue of any present or future law upon such estate or the Inheritance thereof." Bonds of the United States falling within the classification specified will be accepted in payment of estate tax at par and accrued interest. Bonds so receivable must (1) bear a higher rate of interest than four per centum per annum, and 1248 (2) have been owned by the decedent continuously for at least six months prior to the date of his death, and upon such date constitute a part of the estate of the decedent. The reckoning of the required period of ownership may begin on the date when the decedent acquired bonds bearing interest at a higher rate than four per centum, by purchase, by con- version of other bonds, or otherwise. The entire estate tax may be paid in bonds, or the tax may be paid partially in bonds and partially by cash or check. Collectors may not, however, accept bonds, the par value and accrued interest on which aggregates a greater amount than the tax. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 23, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2706.) Compensation for property requisitioned or lost or destroyed through war hazards; replacement fund; taxation deferred — Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue, Revenue Agents and Others Concerned: Regulations No. 33, Revised, provide in Article 94 as foUowa: Art. 04. Income from Damages Becovered. — "When a corporation as a result of suit or otherwise secures pay- ment for damages which it may have sustained, and the amount of such payment is in excess of an amount neces- sary to make good the damage or damaged property, the amount of such excess shall be considered and returned as income for the year in which received. If the entire or an estimated amount of the damage shall have been previ- ously charged off and deducted from gross income, from the amount recovered shall be returned as Income. If the amount recovered Is less than the damage sus- tained or less than an amount necessary to make good the damage, the difference between the actual amount of damage sustained and the amount recovered will be de- ductible as loss. In the case of property, title to which has been requisitioned for war uses, or property which has been lost or destroyed in whole or in part through war hazards, the amount re- ceived by the owner as compensation for the property may show an excess over the value of the property on March 1, 1913, or over its cost if it was acquired after that date. This excess of the amount received over the value or cost of the property, except so far as actually used for the replacement of the property in kind, is subject to the income, war income and excess profit* taxes. Although the intention or obligation of the taxpayer in such case may be to use the entire sum received as com- pensation for the replacement in kind of the lost or damaged property, it is recognized that it may not be practicable, owing to war conditions, to make such replacement for a con- siderable time. In such case the taxpayer may establish A "replacement fund" in which the entire amount of the com- 1249 pensation so received shall be held, and pending the disposi- tion thereof the accounting for gain or loss thereupon may be deferred for a reasonable period of time to be determined by the Commissioner of Internal Revenue. Where the property requisitioned, lost or damaged constituted all or part of the security under a mortgage or trust indenture, the amount car- carried to the replacement fund may, subject to the approval of the Commissioner of Internal Revenue, be the amount of compensation received less the amount, if any, which becomes payable out of such compensation under the terms of such instrument or the obligations thereby secured. In any such case the taxpayer should make application to the Commissioner of Internal Revenue for permission to estab- lish such replacement fund and in his application should recite all the facts relating to the transaction and undertake that he will proceed as expeditiously as possible to replace or re- store such property and an affidavit as to the truthfulness of the statements made should be attached to the application. The taxpayer will be required to furnish a bond with such security or surety as the Commissioner of Internal Revenue may require for an amount not less than the estimated addi- tional excess profits and income taxes assessable by the United States upon the income so carried to the replacement fund; or at the option of the taxpayer and in lieu of such bond the taxpayer may deposit as security for such estimated additional amount of tax, obligations of the United States issued after September 1, 1917, such obligations to be held in trust as such security under such agreement as may be pre- scribed by the Commissioner of Internal Revenue in a bank or trust company approved by him. In any such case when the the replacement or restoration is made the new or restored property shall not be valued in the accounts of the taxpayer at an amoimt in excess of that at which the requisitioned, damaged or destroyed property was carried, except and to the extent that such new or re- stored property has an increased productive capacity. Article 94 of Regulations No. 33 (Revised) as hereby modi- fied shall apply to individuals and partnerships as well as to corporations. DANIEL C. ROPER, Commissioner. Approved: April 25, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2707.) Amending instructions relative to reporting income derived from the sale of personal property on the installment plan — Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: It has been ascertained that dealers in personal property who sell on the installment plan adopt one of four ways of protecting themselves in case of default, namely: 1. A provision that title is to remain in the seller imtil the buyer has performed his part of the agreement. 1250 2. A conveyance of title to the purchaser subject to a lien for the unpaid portion of the purchase price. 3. The conveyance to the purchaser and an immediate recon- veyance by way of chattel mortgage to the seller. 4. Conveyance to a trustee in trust to hold the title pending performance of the contract and subject to its provisions The purpose is the same in all of these transactions. In view of the fact that in a number of States it is held that the form first mentioned shall not be enforced according to its terms, but will be regarded as a sale with a chattel mort- gage back to secure the unpaid purchase price, it is desirable that a uniform rule be established which will be equitable and applicable to all. The rule prescribed is that in the sale or contract for sale of personal property on the installment plan, whether or not title remains in the vendor until the property is fully paid for, the income to be returned by the vendor will be that proportion of each installment payment which the gross profit to be realized when the property is paid for bears to the gross contract price. If, for any reason, the vendee defaults in his installment payments and the vendor repossesses the property, the entire amount received on installment payments less the profit originally returned will be income to the vendor to be so returned for the year in which the property was repossessed. This ruling amends Articles 117 and 120 of Regulations 33, Revised, and revokes all previous decisions and rulings which are in conflict herewith. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 25, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2708.) Estates of Non-residents — Payment of Tax and Transfei of Securities — Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: T. D. 2490 prescribes a method to be followed by transfer agents who have orders for the transfer of stock standing in the name of a non-resident decedent. The following alternative procedure is established for observance by transfer agents who prefer this method to that prescribed in T. D. 2490: A supply of Form 706 will be furnished by the commissioner or any collector of internal revenue to any transfer agent. The transfer agent will forward forms to its foreign offices or to its representatives in foreign countries, with instructions that whenever an order is received for the transfer of securi- ties belonging to a non-resident decedent, the foreign executor, administration or beneficiary of the estate will be required to execute a complete return on Form 706 of all property belong- ing to the decedent situated in the United States, including shares of stock in a domestic corporation. This return, in triplicate, will be subscribed and sworn before a notary public 1251 or a similar officer qualified to administer oaths. If the notary public or other officer is known to the transfer agent and his signature is guaranteed by the transfer agent, the authority of the notary public or other official need not be attested by a certificate of a United States consul. In addition to the returns the foreign representative of the transfer agent will obtain from the personal representative of the estate a copy of the inventory required to be filed by the probate law of the country in which the decedent was domiciled at the time of death, which copy shall be certified to by the proper foreign judicial officer under the same conditions provided for the certification of the returns. The returns and inventory will be forwarded to the United States with the order for transfer of the shares of stock. Upon receipt of the return and inventory by the transfer agent the items on the return will be carefully checked against the inventory. The transfer agent will retain the inventory and send the return, in triplicate, to the Commissioner of Internal Revenue at Washington, with a certificate to the cflTect that all property disclosed by the inventory to be sit- uated in the United States has been included in the return on Form 706. The inventory will be furnished for inspection by the Commissioner of Internal Revenue in any case where the commissioner so desires. After a review of the return and verification of the amount of tax due, two copies of the return will be forwarded to the collector to whom the tax must be paid. Upon payment of the tax the collector will issue the usual receipts in triplicate and in addition will certify on one copy of the return fur- nished him that the amount of tax shown by the return to be due has been paid. The certified and receipted copy of the return will be forwarded with the usual receipts for payment to the transfer agent, to be used as evidence that the securi- ties listed on the return have been reported to the United States Government, and that the Federal estate tax has been paid with respect to all property disclosed on Form 706. Notice on Form 704 and Form 714 must be filed with the collector as heretofore. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: April 25, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2709.) Revoking Treasury Decision 1987; requiring the filing by fiduciaries of a separate ownership certificate where bonds of the same issue are owned by more than one estate or trust, and providing for the filing of one certificate in the case of joint owners. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: 1. Where fiduciaries have the control and custody of more than one estate or trust, and said estates and trusts have as assets bonds of corporations, etc., this office will hereafter 1252 require that a certificate of ownership be executed for each estate or trust regardless of the fact that the bonds are of the same issue. When bonds are owned jointly by several persons, one of the owners may execute an ownership certificate in be- half of the other owners and endorse on the back thereof their names and addresses, and proportion of ownership of each. 2. Treasury Decision 1987, dated May 29, 1914, and instruc- tions on ownership certificates Forms 1000 and 1001, Revised, which provide for the filing of a separate certificate by each joint owner, are hereby superseded and repealed. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: May 2, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2711.) Revision of Article 62 of the Income Tax Regulations and Article 2 of the Excess Profits Tax Regulations regarding limited partnerships. Treasury Department, Office of Commissioner of Internal Revenue. Washington, D. C. To Collectors of Internal Revenue and Others Concerned: Section 10 (a) of the Income Tax Act of September 8, 1916, as amended, provides for a tax upon the net income of "every corporation, joint-stock company or association, or insurance company, organized in the United States, no matter how created or organized, but not including partnerships." Section 4 of the War Income Tax Act of October 3, 1917, and Section 407 of the Capital Stock Tax Act of September 8, 1916, contain language similar in efl'ect. Section 200 of the War Excess Profits Tax Act of October 3, 1917, specifying that when used therein "the term 'corporation' includes joint-stock companies or associations and insurance companies," provides for a tax "upon the income of every corporation, partnership or indi- vidual." Article 63 of the Income Tax Regulations classes limited partnerships as corporations for the purpose of the income tax and requires income from the earnings of such partnerships to be treated like dividends on corporate stock. Article 2 of the Excess Profits Tax Regulations extends the term "corporation" to include limited partnerships. So far as limited partnerships of the type of partnerships with limited liability or partnership associations authorized by the statutes of Pennsylvania and of a few other States are concerned, no reason exists for changing the regulations. Such so-called limited partnerships, offering opportunity for limiting the liability of all the members, providing for the transfer- ability of partnership shares, and capable of holding real estate and bringing suit in the common name, are more truly corporations or joint-stock companies than partnerships. But the regulations require revision with respect to limited partnerships of the type authorized by the statutes of New 1253 York and of most of the States. S'ucri limited partnerships, which cannot limit the liability of the general partners, al- though the special partners enjoy limited liability so long as they observe the statutory conditions, which are dissolved by the death or attempted transfer of the interest of a general partner, and which cannot take real estate or sue in the part- nership name, are so like common law partnerships as to render inadvisable the differentiation hitherto existing in the regulations. The same considerations apply to the classification of lim- ited partnerships for the purpose of the capital stock tax. It is immaterial that partnerships with limited liability of the Pennsylvania type may not issue stock. They have capital stock and the interests of the members are shares within the meaning of the statute, stock certificates being mere evidences of ownership. Therefore, for the purpose of the income tax, the war Income tax, the excess profits tax and the capital stock tax, limited partnerships of the Pennsylvania type of partnerships with limited liability are corporations or joint-stock companies, and limited partnerships of the New York type are partnerships. Article 62 of the Income Tax Regulations and Article 2 of the Excess Profits Tax Regulations are modified accordingly. How- ever, in doubtful cases limited partnerships will be treated as corporations unless thay submit satisfactory proof that they are not in effect so organized. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: Mav 9, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2715). Revision of Articles 83 and 84 of the Income Tax Regulations regarding interest upon the obligations of a State or any political sub-division thereof — Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and others concerned: Section 4 of the Income Tax Act of September 8, 1916, as amended by the Act of October 3, 1917, provides that the fol- lowing income shall be exempt from the income tax: "Interest upon the obligations of a State or any political sub-division thereof." In order more clearly to define this exemption Articles 83 and 84 of the Income Tax Regulations, as revised, are hereby amended to read as follows: "Art. 83. Obligations of a Statei — Among income exempt from the income tax is interest upon the obligations of a State or any political sub-division thereof. Obligations issued for a public purpose by or on behalf of the State or a duly organized political sub-division acting by constituted authori- ties duly empowered to issue such obligations are the obliga- tions of a State or a political sub-division thereof. 1254 "Art. 84. Political sub-divisions.— The term 'political sub- division' denotes any division of the State made by the proper authorities thereof acting within their constitutional powers for the purpose of carrying out a portion of those functions of the State which by long usage and the inherent necessities of government have always been regarded as public. Political sub -divisions of a State, within the meaning of the exemption referred to in Article 83, include special assessment districts so created such as road, water, sewer, gas, light, reclamation, drainage, irrigation, levee, school, harbor, port improvement and similar districts and divisions of a State." DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: May 20, 1918, L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2716.) Amending Article 35, Regulations No. 33 (Revised), by defining foreign items, and regulating the furnishing of informa- tion as to such items by the bank or agency collecting the same, and by the fiscal agent of the foreign country or foreign corporation making the payment. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. 0. To Collectors of Internal Revenue and Others Concerned: (1) Article 35, Regulations No. 33 (Revised), is hereby amended to read as follows: Art. 35. Such returns of information shall be required, regardless of amount, in the case of payments of interest upon bonds, mortgages, or deeds of trust or other similar obligations of domestic or resident corporations, joint- stock companies, associations, and insurance companies, and in the case of foreign items. The original ownership certificates, when duly filed, shall constitute and be treated as returns of information. The term "foreign item," as used In this article, means any dividend upon the stock of a foreign corporation, or any item of interest upon the bonds of foreign countries of non-resident foreign corporations, whether or not such dividend or interest is paid in the United States, or by check drawn on a domestic bank. The term "foreign corporation," as used in this article, means one not organ- ized and existing under the laws of the United States or of any State or Territory thereof, or of the District of Co- lumbia, Porto Rico or the Philippine Islands. The term "non-resident foreign corporation," as used in this article, means any foreign corporation which has no office or place of business in the United States. The mere mainte- nance of an ofllce, or fiscal agency, in the United States for the payment of dividends on stock or interest on bonds, does not constitute a foreign corporation a "resi- dent" of the United States within the meaning of this article. The first bank or agency accepting a foreign item for collection is required to make a return of information con- cerning the same. Whenever a foreign country of foreign corporation making payment of foreign items has a fiscal agent in this country, such agent, when requested by the Commissioner of Internal Revenue, shall furnish whatever information he has in relation to such Items. A dividend- disbursing agent is deemed to be such a fiscal agent. 12S5 Banks or agencies collecting foreign Items are required to obtain a license from the Commissioner of Internal Revenue to engage In such business, and are subject to such regulations for the furnishing of information as said commissioner, with the approval of the Secretary of the Treasury, shall prescribe, and to the penalties prescribed for failure to obtain such license (Act of September 8, 1916, Sec. 9(f), as amended by Act of October 3, 1917, Sec. 1205). A blank application (Form 1017) for such a license may be obtained upon request, from any Collector of Internal Revenue. This license is issued without cost. Such foreign Items shall not be accepted for collection by any bank or collecting agency so licensed unless ac- companied by proper ownership certificates (Form 1001- A) showing names and addresses of the owners, and all other Information called for thereon. The licensee Is also required to Indorse upon such item the words "Certificate detached and Information furnished," adding his name and address. When foreign Items have been Indorsed as above prescribed, the certificates shall be detached and forwarded to the Commissioner of Internal Revenue (Sort- ing Division), Washington, D. C, on or before the twen- tieth day of the month following that during which the Items were accepted, accompanied by a letter of trans- mittal showing the number of certificates, and the aggre- gate amount of foreign items disclosed thereon. (2) For the purpose of complying with the above require- ments, a certificate, Form 1001 -A, will be provided by the Government and furnished to CoUectori of Internal Revenue for distribution to the public. This certificate shall be in the following form: FOREIGN ITEMS. Form 1001-A. Names must be printed U. S. Internal Revenue. or written plainly. Ownership Certificate — Tax Not to be Paid at the Source. (For the use of owners of stock of all foreign corporations, and owners of bonds of foreign countries or non-resident foreign corporations.) Payor of Interest or Dividend. ] Owner of Bonds or Stocks. Name Name Address I Address (On line above give full description of foreign Item — date of dividend, or maturity of Interest. I certify that the owner of the bonds or stock upon which the above-described Income accrued falls within the class of per- sons or organizations opposite which such income Is entered, and Is entitled to receive the income reported without de- duction of tax. Signature of Owner or Agent. Address of Agentf. Owner Int. Diva. If owner Is an Individual Is |If not, Is he I the head of he married? | a family? 1. Citizen or resi- dent of the Unit- ed States, indi- vidual or fiduci- ary* $ 2. Domestic or res- ident corpora- tion, association or partnership— $ 3. Non - resident alien Individual. S 4. Non - resident foreign corpora- tion, association or partnership-- $ |_. ♦Fiduciaries must enter un- der "Owner of bonds or stocks" the name of estate, trust, or beneficiary on behalf of whom this certificate is made. If securities are owned joint* ly by several persons, one may sign, and the names, addresses and proportion of ownership of each indorsed on the back thereof. 1256 NOTE: The first bank or collecting agent receiving this certifi- cate is required to detach and forward it to the Commissioner of Internal Revenue (Sorting Division), Washington, D. C, accom- panied by a letter of transmittal shovv^ing the number of certifi- cates, and the aggregate amount of foreign items disclosed there- on. When certificate is detached, the collecting agent shall in- dorse upon the foreign item "Certificate detached and information furnished ." (Name and address of licensee.) Date tA responsible bank or banker may execute the certificate on behalf of a non-resident alien ov^ner of stocks or bonds. (3) The use of Form 1071, Revised, is hereby discontimied. All Treasury Decisions and other rulings by this office in conflict herewith are hereby superseded and repealed. DANIEL C. ROPER, Commissioner of Internal Revenue. APPROVED: May 28, 1918. L. S. ROWE, Acting Secretary of the Treasury. Printed copies will be furnished upon request. (T. D. 2720.) Income Tax Act of October 3, 1913 — Decision of Court. ASSOCIATION— An organization according to whose constitution in- dividuals who are beneficially interested in various proportions in the same property and hold assignable certificates representing their different interests there- in, but who can claim no part of the income of such property as their income as distinguished from the income of the organization to which they belong, commit the control and management of such prop- erty, or for profit, to trustees, free from their own immediate control or interference, except that such individuals may act by majority in amount and in- terest for the purpose of allowing extra compensa- tion to the trustees, filling vacancies in the office of trustees or modifying the terms of the declaration of trust, is an "association" and taxable as such under Section II. G(a) of the Act of October 3, 1913. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Circuit Court of Appeals for the First Circuit in the cases of Crocker et al., trustees, v. John F. Malley, collector of internal revenue, and of John F. Malley, collector of internal revenue, v. Crocker et al., trustees, is published for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved June 4, 1918: L. S. ROWE, Acting Secretary of the Treasury. 1257 UNITED STATES CmCUIT COURT OF APPEALS, FIRST CIRCUIT, OCTOBER TERM, 1917. 1917. No. 1323. No. 1324. Alvah Crocker et al., trustees, plaintiffs in error, v. John F. Malley, collector, defendant, defendant in error; John F. Malley, collector, defendant, plaintiff in error, v. Alvah Crocker et al., trustees, plaintiffs, defendants in error. Error to the District Court of the United States for the District of Massachusetts. Before Dodge, Johnson and Aldrich, Judges. (May 3, 1918.) Dodge, Judge: These cases arise under the Federal Income Tax Act, approved October 3, 1913 (38 Stats. 166, 172). The j&ve persons who were then the trustees under a declara- tion of trust dated March 29, 1912, and recorded in the Worcester County, Massachusetts, Northern District, registry of deeds, brought suit on January 15, 1917, against the Col- lector of Internal Revenue to recover back certain amounts paid by them to him under protest, as income taxes claimed by him to be due from them under said act, for the years 1913, 1914 and 1915. The case was heard in the district court without a jury on an agreed statement of facts. The trus- tees recovered judgment for $9,554.07, with interest, which judgment the collector seeks to reverse in No. 1324, asserting that the allowance of any recovery was error. By their writ of error in No. 1323, the trustees assert the judgment to have been erroneous in not allowing also the further recovery of $1,321.33, included in their total claim as stated in their declaration. Neither party disputes the finding below that all the formalities required by the statute to enable the plain- tiffs to bring this suit have been complied with. The declaration of trust provided that "the title of this trust (fixed for convenience) shall be The Wachuset Realty Trust," The important features of the trust thereby created are set forth as follows ui the "Opinion and Findings" of the district court: The trust was created under the common law. In Its Inception there were five trustees and eight beneficiaries, five of whom were trustees. The property of the trust consisted of real estate and shares of stock In a Massachusetts corporation, the legal title to which was vested in the trustees. The real estate was leased to the Massachusetts corporation, and the income of the trust came from the dividends on the stocl^ and the rentals of the real estate. Certificates were issued by the trust to the beneficiaries in proportion to their respective Interests in the property held by the trust. The certificates contained a provision signifying the assent of the beneficiaries to the terms of the trust agreement. According to the trust agreement, the trust was to continue for 20 years from and after the death of the survivor of certain per- sons named, when the property was to be converted Into money and the net proceeds distributed among the persons then holding and owning the beneficial interests therein. Pending final con- version and distribution of the property full management and control of the tame was vested in the trustees, with as full Sowers as though they were themselves sole and absolute bene- cial owners thereof in fee simple. They were authorized to collect and receive all rents and In- comes from the property and semi-annually or oftener to dis- tribute such portion thereof as they, In their discretion, should determine to be fairly distributable as Income to the several cestui que trusts, according to their Interests. The compensation of the trustees was not to exceed a total of one per cent, reckoned upon the gross income received, "unless, at any time, a majority In interest of the cestui que trusts consent in writing to gome 1258 larger compensation for any past service." Any vacancies in the office of trustee were to be filled by tlie remaining trustees by an instrument in writing signed by them and assented to in writing by the holder or holders of a majority in amount of the beneficial interests in the trust; and the terms and provisions of the trust could be modified at any time by an instrument in writing, signed, sealed, and acknowledged "by the then trustees, assented to in writing by a majority in interest of the cestui que trusts." It was also stipulated that the cestui que trusts should "be trust beneficiaries only, without partnership, associate, or any other relation whatever inter sese." The district court stated the question upon which the trus- tees' right of recovery depends as follows: The principal question in the case is whether the plaintiffs are trustees and subject to the tax provisions of Section II., Subdivi- sion D, of the Act of October 3, 1913, or whether they are an association within Section II.. Subdivision G(a), of said act. The contention of the defendant is that the plaintiffs are an associa- tion and taxable under the provisions of Subdivision G, while that of the plaintiffs is that they are a strict trust, not an asso- ciation or partnership, and are subject to the tax provisions of Subdivision D. This question was resolved by the district court in favor of the plaintiffs, and the case decided upon the ground that they are a trust and not an association. Under the corporation excise tax statute of 1909 (36 Stats., 11, 112) every corporation, joint- stock company, or associa- tion organized for profit and having a capital stock represented by shares, now or hereafter organized under the laws of the United States or of any State or Territory, etc., was made subject, if engaged in business in any State, etc., to pay an- nually a special excise tax with respect to the carrying on or doing business by it, of 1 per cent upon its entire net income over and above $5,000 received by it from all sources during the year. In Eliot V. Freeman, 220 U. S., 178, it was held with regard to two Massachusetts real estate trusts, more or less similar in character to the trusts here under consideration, that they were not within the provisions of the act nor liable to the excise tax thereby imposed because formed in a State where statutory joint- stock companies are unknown and not there- fore deriving either from the laws of the United States or of any State or Territory, etc., and quality or benefit not existing at the common law. The intention of Congress was held to have been to embrace within the statute only such corporations and joint- stock associations as were organized under some statute or did derive from that source some qual- ity or benefit not existing at the common law. This decision was in 1911. The language of the subsequently enacted income tax statute of 1913 imposes the normal tax therein provided for upon the entire net income of every corporation, joint- stock company, or association organized in the United States, no matter how created or organized. If, therefore. The Wachuset Realty Trust is a joint- stock company or association, within the meaning of those terms as used in Section 11., G(a), of the statute of 1913, it makes no difference whether it is created or organized under any statute or not. Being organized in the United States its income is liable to the tax imposed, although it derives no benefit not existing at common law from any statutory source. The question remains, however, whether or not the facts before the district court required the finding that it was a "joint- stock association" or "association" such as the above section intends. We find no indication in Eliot v. Freeman or in any other Supreme Court decision that a Massachusetts trust like 1259 those before the court in that case must necessarily be re- garded as such an "association" in the statutory sense. On the collector's behalf it is said that in the legislation of 1913 Congress "intentionally omitted the one requirement which exempted such an organization" under the legislation of 1909. But we think it by no means clear from anything said in the opinion that either trust before the court in Eliot v. Freeman must have been held an "association" in the statutory sense, had it only been organized under some statute expressly per- mitting such organization. In the opinion it is expressly said, as to the trusts then under consideration, that they could "hardly be said to be organized within the ordinary meaning of that term" (220 U. S., 186), and it was pointed out (at p. 187) that they did not have perpetual succession, but ended 2.0 years after lives in being — suggestions which would hardly have been made if the decision was meant to be understood as contended. With regard to the statute of 1909 it is to be noticed that while corporations, joint- stock companies, or associations and insurance companies, were therein classed together as they are in the statute of 1913— the former statute, unlike the lat- ter, imposed upon them not a tax upon their incomes as such, but a "special excise tax with respect to the carrying on or doing business by them," equivalent to 1 per cent upon their net incomes in excess of $5,000. Upon partnerships, not capa- ble of being included in said classification, the statute of 1909 did not undertake to impose any such tax, any more than upon individuals. The incomes of the partners from the busi- ness of an ordinary partnership Congress could not have taxed in 1909; the sixteenth amendment not having become a part of the Constitution until February 25, 1913. The statute of 1913, however, imposes a tax directly upon net incomes not a special excise tax equivalent to the same percentage. It imposes such tax directly upon the incomes of individuals and partnerships as well as those of corpora- tions, joint-stock companies or associations, and insurance companies according to provisions alike in principle as to all said incomes, however different as to matters such as the dif- ferent amounts of exemptions or deductions allowed different classes of recipients. The provisions of Section II., G(a), which subject the incomes of corporations, joint-stock com- panies or associations, and insurance companies to the tax are there expressly declared not applicable to partnerships. In Section II., D, are found separate and distinct provisions which expressly direct that persons carrying on business in partnership shall be liable for income tax only in their indi- vidual capacities, and which regulate accordingly the returns of incomes required to be made by partnerships. No provisions are found in the statute of 1913 which directly impose a tax upon incomes arising or accruing to fiduciaries, in terms corresponding to those whereby a tax is imposed upon incomes arising or accruing to individuals (Sec. IT., A-1) or to corporations, joint-stock companies or associations, etc. (Sec. IL, G-a). By Section II., I>, in a paragraph mainly devoted to setting forth requirements t)f annual returns froin or on behalf of the various classes of recipients of taxable income, trustees, among other specified kinds of fiduciaries, "and all persons, corporations, or associations acting in any fiduciary capacity," are required to make such returns of "the net income of the person for whom they act, subject to this tax, coming into their custody or control and managemeit, 1260 and be subject to all the provisiona of this section which apply to individuals." The provisions just referred to seem to be rather provisions for the assessment and collection of the taxes due from the different classes of recipients of incomes elsewhere directly taxed by the statute than provisions creating still another class of recipients and imposing a tax upon incomes arising or accruing to them. Nowhere in the statute are incomes arising or accruing to fiduciaries declared subject as such to the provisions taxing incomes arising or accruing to indi- viduals. In view of the above features of the statute, the nrst ques- tion presented in determining its application to these trustees seems to be as follows : Is the income received by them dur- ing each calendar year from the property under their control to be considered income arising or accruing to the "persons for whom they act," or as income arising or accruing to them, notwithstanding that it is to be disposed of by them as the trust declaration requires? If it is to be regarded as income of the former description, i. e., as arising or accruing to the respective beneficiaries, the above provisions of Section II., D, require an annual return of it from them, and they are liable to pay the tax imposed upon it by a clause in the same para- grapgh subjecting them to all the provisions of the section applicable to individuals; but under subsequent provisions of Section II., D, they need not include in their returns so much of said income as is derived from dividends upon the stock forming part of the property under their control. But if said income is to be considered as "arising or accruing" to them rather than to the beneficiaries or certificate holders, none of the above provisions of Section II., A, or of Section II., D, seem to us applicable either to said income or to them. Though arising or accruing to them as trustees or title holders of the property from which it is derived, they do not, and could not, claim such income as their own in any individual capacity; and if they do not receive it as income subject to the tax because it has arisen or accrued to the several bene- ficiaries, it must be either income arising or accruing to them collectively as the receiving officers of their organization, and subject to the tax imposed by Section II., G-a, upon incomes of the different class there dealt with, from which dividends may not be deducted, or income upon which no tax is imposed by any express and distinct provisions of the statute. In order to make income from a trust estate received by the fiduciary in any calendar year income of the person for whom he acts, subject to the tax, in the sense of the above provi- sions of Section II., D, it must be received by the fiduciary upon terms which make it income arising or accruing during that year to such person according to Section II., A-1. If the terms of the trust are such that its receipt by the fiduciary immediately renders it, or so much of it as is net income, available as such to the beneficiary, no difficulty is found in regarding it as income of the person for whom the fiduciary acts, subject to the tax, coming into his custody or control and management, and therefore governed by said provisions of Section II., D. But by the terms of the trust here in question the receipt by the trustees during a given calendar year of income from the trust estate does not render any part of such income immediately so available to the beneficiaries as income arising or accruing to them during the year. Such receipt gives to 1361 no one of them any right to a share of what the trustees so receive as then belonging to him individually, or any right to direct the disposition of any such share according to his individual determination. The plaintiffs were not required by the trust declaration under which they received the income from the trust estate for the calendar years here in question to distribute it, or any part of it, to the beneficiaries, as net income, at any time. The requirements as to distribution are only that they dis- tribute such portion of the income received "as they may in their discretion determine to be fairly distributable net in- come." And they are given full authority from time to time to devote any funds on hand, whether received as capital or income, to repair, improvement, protection, or development of the property under their control, or to the acquisition of other property, as they "may determine to be wise and expedient for the protection and development of the trust property as a whole pending its conversion and distribution." Further, their determination is expressly made final, if made by them in good faith, as to all questions as between capital and income. No beneficiary of this trust, therefore, had the right, when the income for a given calendar year from the trust property came into the plaintiffs' hands, to demand any share of it or direct the disposition of any of it or even to have his individ- ual share of it determined. To the plaintiffs, and not to their beneficiaries, belonged the right to say whether any of it should then go to the beneficiaries or whether all of it should become part of the trust property ultimately to be distrib- uted. In such final distribution no one who was a beneficiary during the calendar year might live to share. While the value of his proportionate interest in the trust estate might be in- creased if income for the year went to augment said estate, his proportionate share in income so disposed of can hardly be called income arising or accruing to him as an individual dur- ing the year, in the ordinary sense. We think it may \vell be doubted whether income, received by the plaintiffs, subject to such independent power of disposition, or any part thereof, is income within the meaning of the language in Section 11., D, "the net income of the person for whom they act, subject to this tax, coming into their custody or control and manage- ment." The plaintiffs' powers and functions as defined by the in- strument under which they act resemble the powers and functions ordinarily exercised by the managers of an organi- zation so constituted as to be of itself a recipient of taxable income independently of the individuals beneficially interested in the property from which it is derived, much more than they resemble the powers and functions of ordinary fiduciaries act- ing merely as such for ordinary beneficiaries. Particularly is this true as to income received from their trust estate. Until and unless, after its receipt, they have so exercised their dis- cretion as to determine it, or some part of it, to be fairly dis- tributable net income, no individual for whom they act can claim any part of it as his income, as distinguished from the income of the organization to which h-e belongs. The same is true of a corporation's income, in which stockholders can claim no individual right before the managers declare a divi- dend from it. The same would be true of a corporation, joint- stock company, or association which had given to its officers powers of disposition over its income like the above. The 1263 same would not be true in the ordinary eases of fiduciaries exercising, with regard to income, only the powers necessary for distributing net income as received to the persons for whom they act, such as we think were contemplated by the above provisions of Section II., D. It is true, as the agreed statement before us shows, tliat the plaintiffs "have disbursed such income" as they have from time to time received from the real estate and stock which they hold, "less charges and disbursements for taxes and similar expenses, to their several beneficiaries in proportion to their respective interests." This we understand to mean that they have distributed so much of the income received by them during the calendar years here in question as they determined in their discretion, to be fairly distributable net income; ac- cording to clause 3 of the declaration of trust. But in said distributions the respective beneficiaries can hardly be said to have got what they received because it had arisen or ac- crued to each of them during the year; or the plaintiffs to have been performing only the duty of paying over net in- comes so arising or accruing. Each beneficiary took what he received, not because it was his net income so arising or accruing, but because the plaintiffs had elected to treat what they distributed as "fairly distributable net income," instead of accumulating it as they might have done. The district court, as its opinion states, held the plaintiffs to be "a trust" subject to the provisions of Section II., D, and not "an association," in deference to the decisions in Williams T. Milton, 215 Mass. 1; Crocker v. Crocker, previously decided in the district court (May 23, 1914), and the authorities where- upon those decisions were based. Crocker v. Crocker required construction by the court of the same trust declaration as is now before us. The bill in that case, filed by one of the bene- ficiaries, asked the court to enjoin the present plaintiffs from making a return of income taxable under this statute accord- ing to Section II., G-a, thereof. We agree with the district court, in this case and in Crocker V. Crocker, that the organization formed under this trust dec- laration is not, in view of the authorities referred to, to be regarded as an association in such sense as to make the bene- ciaries partners and the plaintiffs their agents for conducting the partnership business. Its income, therefore, for the calen- dar years in question, is not for the purpose of the statute to be treated as income of a partnership. If it were to be so treated it would be income arising or accruing to the several partners and subject to the provisions of Section II., D, re- garding such income. Nor could the organization be regarded as belonging to either of the classes mentioned in Section II, G-a, because the language there used expressly excludes partnerships. But although their beneficiaries stood, neither as to the trust property nor as to the profits of its control and management, nor as to the income therefrom, as partners, but only as beneficiaries of a struct trust; and although the plaintiffs were not the agents or representatives of a partnership, but trus- tees in whose management and control of the trust property and business the beneficiaries had no direct voice, we do not think it necessarily follows that the organization composed of themselves and the individuals for whose benefit they act can not be called an "association" for the purposes of Section n., G-a. Though not associated as partners, we fail to see why they may not reasonably be said to be associated in the 1263 sense contemplated by the statute. As pointed out above, the statute, for the purposes of the taxation which it imposes, broadly distinguishes between two classes of income only — that which does and that which does not arise or accrue to individuals as opposed to groups or bodies of individuals. The plaintiffs fail to satisfy us that the terms ''voluntary association" or "association" are entirely inapplicable for any purpose to an organization according to whose constitution individuals beneficially interested in various proportions in the same property commit its control and management, for profit, to trustees free from their own immediate control or inter- ference. However important it may be to distinguish between a trust under which there is no partnership relation among the beneficiaries and an association imder which such relation exists for the purposes of systems of taxation such as that of Massachusetts (Williams v. Milton, 215 Mass., 1), or for the purpose of statutes such as that construed in Smith v. Ander- son, 50 L. J. Ch., 39; it does not seem to us that the dis- tinction 80 made necessarily excludes an organization like this from the general class of organizations to which the terms "voluntary association" or "association" may properly be ap- plied. The holders of the assignable certificates representing the different beneficial interests in this "trust" may certainly be described, without using language in any extraordinary or unusual sense, as associated together for their common benefit or profit. Their individual interests in the trust prop- erty are combined for the purposes of a joint business venture managed for the common benefit of all. The trust declaration in effect associates them for the purposes of allowing extra compensation to the trustees, of filling vacancies in the office of trustees, or of modifying the terms of the declaration itself when it requires for those purposes written assent from a "majority in amount" or a "majority in interest." Believing, in view of the entire scheme for taxation of in- comes as established by this statute, that the legislative intent as to incomes such as these plaintiffs have received was to treat them as arising or accruing to the trustees collectively, rather than to the individual beneficiaries for whose ultimate benefit they were received, we are obliged to hold that the taxes for the years here in question were lawfully assessed and collected, and that the district court erred in its decision to the contrary. This conclusion renders it unnecessary to consider the questions w^hich would have had to be decided upon the plaintiffs' writ of error No. 1323 had we agreed with the district court. In No. 1323 the writ of error is dismissed, and the defendant in error recovers his costs of appeal. In No. 1324 the judgment of the district court is reversed, and the case is remanded to that court with directions to enter judgment for the defendant, and the plaintiff in error recovers his costs of appeal. (T. D. 2721.) Corporation Excise Tax Act of 1909— Decision of the Supreme Court — 1. Nature of Iron-Ore Leases. Iron ore leases of the kind under consideration are not conveyances of the ore in place, but are grants of the privi- lege' of entering upon, discovering, and developing and re- 1264 moving the minerals from the land — The Sargent Land Com- pany case (243 U. S., 503) followed. 2. Depletion of Capital Assets. The lessee of mining property may not deduct the pro- portionate value of the ore in place on January 1, 1909, with respect to each ton of ore mined, as so much depletion of capital assets, but may deduct a proportionate part of the royalty paid in advance. 3. Judgment Reversed. The judgment of the Circuit Court of Appeals is reversed and that of the District Court is aifirmed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court in the case of United States of America v. Biwabik Mining Company is published for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved June 4, 1918: L. S. ROWE, Acting Secretary of the Treasury. SUPREME COURT OF THE UNITED STATES. No. 594. OCTOBER TERM, 1917. United States of America, petitioner, v. Biwabik Mining Company. On writ of certiorari to the United States Circuit Court of Appeals for the Sixth Circuit. (May 20, 1918.) Mr, Justice Day delivered the opinion of the court: This case is here upon a writ of certiorari to the United States Circuit Court of Appeals for the Sixth Circuit. It was instituted by the United States in the District Court of the United States for the Northern District of Ohio to recover the sum of $2,653.72, being 1 per cent upon $365,372.08, which, it was claimed, the mining company had wrongfully omitted from the return of its net income for the year 1910 under the corporation tax act of 1909. The case was tried upon an agreed statement of facts which, omitting imnecessary details, were epitomized by the District Court as follows: In the year 1898 the defendant, by assi|?nment of a lease, ac- quired a leasehold estate in certain ore-prodncing properties in the State of Minnesota, from whirh It mined ore from thnt date to and including? the year 1910. For the year 3930 the dofendnnt made a retnrn to the collector of internal revenue of its gross Income, and from this amount it dpducted, "to cover realization of nnfarned increment," the sum of $265,372.08. The amount of this deduction was arrived at by mnltiplylncr the number of tons of ore mined during the year by 48% cents, which was the market value of the ore in place on the premises on the first day of January, 1909, as estimated by the defendant, this being the date upon which the returns for taxation were to commence. It is stipu- lated that this deduction Avas made in good faith upon the claim that it was "a reasonable allowance for depreciation" of the prop- erty of the defendant for that year. 1265 In June, 1911, payment was made In accordance with this re- turn, but the Treasury Department about the month of October, 1914, after investigating the books and records of the defendant, made the claim that because the defendant was not the owner in fee of the premises from which it was mining ore, but was lessee of the same and was paying a royalty to the fee owners, It was not entitled to deduct anything for depletion of the ore body on the premises. Thereupon the defendant was requested to amend its return for the year 1910 so as to include in its gross Income the amount of said deduction, which it declined to do, and thereupon this suit was instituted to recover the tax upon the amount of this deduction, amounting to $2,653.72. Some time prior to the making of the return for the year 1910 the defendant estimated the tonnage and the market value of the ore In place upon the premises upon which it held its lease, which estimate gave to the ore in place a value of 4S% cents per ton, exclusive of royalty. The rights of the defendant in the Iron ore mined In the year 1910 were derived from the assignment to it of a written lease dated April 4, 1898, by the Biwabik Bessemer Company, lessor. By the terms of that lease the defendant acquired the right for the term of 50 years and 3 months from the first day of May, 1898, to explore for, mine out, and remove the merchantable shipping iron ore which might be found upon the lands described In the lease upon the payment of a royalty of 30 cents for each ton mined. The expression "merchantable ore" is defined as including "all ores which grade 55 per cent and above in metallic iron regardless of other ingredients." The lessee contracted to mine and remove at least 300,000 toui of ore annually, or to pay to the lessor 30 cents per ton on that amount if it should not be mined, but payments made In any year in excess of royalty on ore actually mined could be credited upon the excess which might be mined over the minimum re- quirement In subsequent years. Any failure to keep or perform any of the covenants or conditions of the lease gave to the lessor the option to take Immediate possession of the premises. The lessor in the lease reserved a lien upon any ore mined and upon all improvements for any unpaid balance of royalty, and It was also provided in the lease that the lessee should have the right to terminate the lease on any first day of January during its term by giving 90 days' notice of the purpose and desire so to do. The defendant, at the time it acquired this lease, paid to the prior lessee the sum of $612,000, In addition to contracting to pay the 30 cents per ton royalty upon the ore mined, as has been Btated. It Is stipulated In the agreed statement of facts that the deposit of ore on the leased premises is of such character that its quality and quantity were capable of determination "with extraordinary accuracy" by drilling and shafts, and that the defendant "by drilling and by standard recognized methods" had calculated the tonnage remaining on the land on January 1, 19C9, as 6,874,605 tons, all of which could be easily removed within the term of the lease. Upon these facts the district court reached the conclusion that the leases in question were not conveyances of ore in place, but were grants of the privilege of entering upon the premises and mining and removing the ore, and, consequently, that the deduction claimed as being one from capital invest- ment could not be allowed. In reaching this conclusion the court cited the opinion of this court in Stratton's Independ- ence (Ltd.) V. Howbert, Collector (231 U. S., 399), and the judgment of the Circuit Court of Appeals for the Eighth Circuit (311 Fed., 1023) affirming the judgment of the district court (207 Fed., 419), which decision of the Circuit Court of Appeals was made after the return of the answer to the ques- tions propounded by that court to this court in the Stratton's Independence case. Coming to the question as to whrtt allowance should be made to the mining company by way of deduction from its income in making return, the district judge said: The defendant paid $612,000 for the lease under considera- tion and in addition assumed the payment of the royalties stipulated for therein. This may properly and justly be con- 1266 sidered a payment in advance of an increased royalty on ore to be mined, and that is precisely the character which the defendant gave to the payment when dealing with it in its private accounts, in which the stipulation shows (Ex. H.) that it carried one account, entitled "Rate of general ledger or capitalized value $0,03885 per ton," and another account en- titled "Rate of increment value, January 1, 1909, $0.44865 per ton." These two values added make the 48% cents per ton which the defendant deducted in making its return. Thus, in its own bookkeeping the defendant gives its private opinion as to the requisite reimbursement necessary to main- tain its capital investment, and thereby is made applicable that long-standing rule for the construction of contracts, viz. : "Show me what men have done under a contract, and I will tell you what it means." The defendant should not complain if it be held to that construction of this lease and its invest- ment under it which it adopted for purposes of its own ac- counting before the question of taxation had arisen to call forth ingenuity of interpretation. It results that a decree will be entered allowing instead of the deduction computed on the basis of 48.75 cents per ton of ore mined, the sum of 0.03885 cent per ton, and there being no question of bad faith in the case, the ends of justice will be served by the payment of interest at the rate of 6 per cent per annum from the date when the additional payment found due should have been made. The district court thereupon entered judgment: And the court finds as conclusions of law from said facts that the defendant was entitled to deduct for and on account of the 544,353 tons of iron ore mined by it under its lease in the year 1910, the sum of 0.03885 cents per ton (which amount the parties agree hereoy is the cost to defendant of said ore at the time it acquired the property in the year 1898, interest, taxes, surveys and other carrying charges on the said ore up to the time of its removal from the said mine having been charged annually including the year 1910 into operating expenses), and defendant is not entitled to deduct the 48,75 cents per ton deducted by it In its return, and there is due from the defendant to the plaintiff the sum of $2,442.23, with interest thereon at 6 per cent from the 30th day of June, 1911, the date when said sum should have been paid, and the court assesses the plaintiff's damages herein at $3,140.70, and judgment is hereby rendered against the defendant in favor of the plaintiff of the sum of $3,140.70, with interest from the first day of this term of court. The company took the case to the Circuit Court of Appeals upon writ of error, that court reversed the judgment of the district court, holding that the company was entitled to the deduction of 48.75 cents per ton upon each ton of ore mined, as so much depletion of capital assets (242 Fed,, 9). This con- clusion was reached upon a construction of the lease in view of the character of the mining property involved, and largely because of the fact that the quantity of the ore in place could be estimated with substantial accuracy. The court held that the selling price of the ore in any one year so far as it rep- resented the actual value to the mining company of the ore in the ground on January 1, 1909, was not income within the meaning of the corporation tax act of 1909. In the course of its opinion the Circuit Court of Appeals announced the de- cisive question of law to be: "So far as the selling price of the ore in 1910 represented its actual value to the company in the ground on January 1, 1909, was it income or was it the sale price of capital assets?" And after dealing with the character of this lease and the property covered by it, said: 1267 We think that the lessee of such property and under such a lease Is as much entitled as Is the owner of the fee to treat the value of his interest In the ore in the ground at the beginning ol the tax period as his capital — Indeed, the lessee's right to do so is, In some respects, the stronger of the two, as hereafter pointed out. Such a lease, as applied to this situation, is in every substantial way pro tanto a purchase. This view of the character of these instruments and their legal effect differs from that taken by this court in the Sar- gent Land Company case (242 U. S., 503), wherein precisely similar iron ore leases were under consideration. In that case this court reached the conclusion that such leases were not conveyances of the ore in place, but were grants of the privilege of entering upon, discovering, and developing and removing the minerals from the land, and that the lessor's income from such operation was obtained by a corporation shown to be carrying on business, and upon principles laid down in previous cases in this court (Stratton's Independence V. Howbert, supra; 'Stanton v. Baltic Mining Company, 240 U. S., 103) that such income was subject to taxation under the corporation act of 1909. In the Sargent Land Company case it was pointed out that the courts of Minnesota, certainly familiar with the physical characteristics of the ore deposits involved, had in a series of cases held these instruments to be leases, and that the royal- ties agreed to be paid were rentals in compensation for the privileges granted the lessee. We held the conclusion of the Minnesota courts to be warranted by reason and authority. (242 U. S., 503, and cases cited in margin, p. 518.) The Circuit Court of Appeals distinguished the Sargent Land Company case, and of it said: Finally, It Is urged that this case Is controlled by the decision of the Supreme Court In the Sargent Land Company case. The mining leases involved in that case and in this one seem to be iden- tical in substance, and It is now said with great plausibility that the ore in the ground and affected by such a lease belongs partly to the lessor and partly to the lessee, and that if the interest of the lessor Is not capital assets no more is the interest of the lessee, and that If the receipts of the former are income so must those of the latter be. We are convinced that the analogy between the two cases is superficial and not substantial. In that case the Supreme Court had to determine Avhether the royalties re- ceived by the lessor were income or were a depletion of capital. Many considerations led to the conclusion that they must be treated as income. The contract was a "lease," the receipts were "royalties," and royalties being rentals are inherently Income and have been commonly so considered. All these things seem to have affected the conclusion of the court, but after all the dominating thought appears to be that when land Is devoted to mining it Is put to only one of those productive uses of Avhich it is capable, and that the product of the use should be called Income. The land Itself Is the chief thing. After the mining is finished the land remains suitable for other uses; and the fact, If it Is a fact, that the minerals are the greater part of its value can not operate to make the Incidental overshadow the principal. These reasons do not apply at all to the case of the lessee whose existing interest at the beginning of the taxing period over and above the royalty which he must pay amounted to $3,000,000; his entire interest was each year, as far as he went, consumed and exhausted forever; he did not have remaining the principal thing— the land— which he could put to some other use; the receipt In 1910 of his Janu- ary 1, 1909. Interest in the ore was not the offshoot and Income of his property; it was the transformation and eating up of the very property and of the whole of It. We therefore think that applying the principle of the Sargent case results in holding that these receipts were from the sale of capital assets and not from income. We are unable to concur in this view expressed in the opin- ion of the Circuit Court of Appeals as to the effect of the Sargent Land Company case. Certainly this court had not in 1268 mind the distinction suggested. In the Sargent Land Company- case the Circuit Court of Appeals for the Eighth Circuit found that the land including the ore in it was worth hundreds of thousands of dollars, and without the right to the ore the land was worth practically nothing. (219 Fed. 38.) This finding, as well as facts of general knowledge, leave little room to suppose that this court made its decision concerning the rights of the lessor influenced by the fact that the land itself was the chief thing, and the ownership of it after the exhaustion of the minerals one of the controlling reasons in reaching the conclusion announced in that case. The lessee takes from the property the ore mined, paying for the privilege so much per ton for each ton removed. He has this right or privilege under the form of lease here involved so long as he sees fit to hold the same without exercising the privilege of cancellation therein contained. He is, as we held in the Sargent Land Company case, in no legal sense a purchaser of ore in place. In this case the Government took no writ of error as to the partial deduction allowed by the District Court, it follows that the correctness of that ruling is not open here. The Circuit Court of Appeals erred in making the additional allow- ance for capital depletion.. It follows that the judgment of the Circuit Court of Appeals must be reversed, and that of the District Court affirmed, and it is so ordered. Reversed. Mr. Justice Clarke took no part in the consideration or decision of this case. (T. D. 27^2.) Corporation Excise Tax Act of 1909— Decision of the Supreme Court — 1. Depletion of Ore Bodies. For the purpose of determining its net income for the basis of taxation under the act, a mining corporation is not entitled to deduct from its gross income any amount what- ever on account of depletion or exhaustion of ore bodies caused by its operations for the year for which the tax is assessed. 2. Deduction of Cost Value of Ore in Ground. In the ascertainment of its net income under the act, a mining corporation is not entitled to a deduction against gross proceeds from the mining and treatment of ores to the extent of the cost value of the ore in the ground before it was mined, ascertained in compliance with T. D. 1675. 3. Questions Answered. The questions propounded by the Circuit Court of Appeals are answered as above specified. Treasury Department, Ofiice of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court in the case of the Goldfield Consolidated Mines Company v. 1369 Joseph J. Scott, as collector of internal revenue, is published for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved June 4, 1918: L. S. ROWE, Acting Secretary of the Treasury. SUPREME COURT OF THE UNITED STATES. No. 334. OCTOBER TERM, 1917. Goldfield Consolidated Mines Company v. Joseph J. Scott, as collector of internal revenue. Fourth California District. On a certificate from the United States Circuit Court of Appeals for the Ninth Circuit. (May 20, 1918.) Mr. Justice Day delivered the opinion of the court: This case is here upon certificate from the United States Circuit Court of Appeals for the Ninth Circuit, from which it appears that the Goldfield Consolidated Mines Company brought an action against Scott, United 'States collector of internal revenue, Fourth California District, to recover certain taxes levied for the years 1909 and 1910 imder the corpora- tion tax act of 1909. The District Court sustained a demurrer to the complaint, and entered judgment against the present plaintiff in error. In the certificate the Circuit Court of Appeals sets out the allegations of the complaint as to the first cause of action, stating that the second cause of action need not be repeated as the facts are of the same character as those set out in the first. Omitting formal and unnecessary matters the Circuit Court of Appeals certifies as the allegations of the complaint, to which the demurrer was sustained, the following. The plaintiff below, and plaintiff in error herein, the Goldfield Consolidated Mines Company is and was a corporation engaged in mining in the State of Nevada, which State is within the juris- diction of the fourth internal revenue district of California. An assessment of an excise tax under Section 38 of the Act of Congress approved August 5, 1909, entitled "An Act to Provide Revenue, Equalize Duties, and Encourage the Industries of the United States, and for other purposes," was levied upon the plaintiff in error by the then collector of internal revenue for the said district amounting to $41,890.91, upon an assessment of $4,189,091.61 which tax was paid under protest of the levy and assessment. The plaintiff in error had made a return of annual net income for that year, 1909, claiming a deduction for the value of the ore in the ground before it was mined, of 230,4(i3 tons of ore, of the value in the ground before it was mined, of $.'),64G,940.46, upon the ground that such ore constituted exhaustion of the capital value of the property owned by it, and its protest against the assessment and levy was based thereon. Thereafter, the plaintiff in error made application for refund of said tax pur- suant to Sections 3220 and 3226 of the Revised Statutes, and based its claim to such refund upon the propriety of the deduction so claimed, and stated in said application that such exhaustion of capital assets constituted a depreciation within the meaning of the Act in question, and that the same would have more than offset the total net income of the plaintiff in error. Thereafter, during the pendency before the Commissioner of Internal Revenue of said application for refund, the plaintiff in error, by its duly authorized officials, made full explanation before the Commissioner of Internal Revenue, and offered full proof of the correctness in all respects of its said return of annual net in- come for the year 1909 and of all statements of fact contained therein, and while the Commissioner of Internal Revenue was holding said application under consideration the plaintiff in error 1270 was duly and regularly granted by said commissioner leave to comply fully with the then rules and regulations of the Treasury Department embodied in Treasury Decision 1675, promulgated February 14, 1911, and particularly Sections 80 to 89 thereof re- lating to depreciation of property of corporations whose business involved wasting assets and like leave was so given to present to the Commissioner of Internal Revenue an amended statement and return of annual net income for said year with explanations of fact in support thereof, and to ascertain the unit cost per ton of the estimated ore bodies belonging to the plaintiff in its various mining properties as of January 1, 1909, and the estimated value of the ore in the ground before it was mined for the year 1909, by multiplying the said unit cost per ton by the total number of tons mined in said year, all of which was done, and the same was filed by the plaintiff in error during the time so provided. The rules and regulations are then set out. In addition to the rules and regulations as above set out, the flaintiff in error was further required by the Commissioner of nternal Revenue to make a calculation for the year 1909 and of previous years of operation to ascertain the total exhaustion of ore which had taken place in the operation of its mining proper- ties, and to enter such amount of tonnage exhaustion, multiplied by the unit cost per ton, in its official corporate books of ac- counts, and also cause the same to be included in its printed annual report of that current year to its stockholders and the public with appropriate explanation thereof, all of which require- ments were performed by the plaintiff in error in obedience to said orders of the Commissioner of Internal Revenue, and within the time granted therefor. The complaint alleged that the resulting figures so rendered In said return were and are in all respects true and correct, and resulted in a showing of net income measuring the excise tax under the rules and regulations amounting to $765,380.02, upon which the tax would have been $7,653.80; it also appeared from said complaint that this compliance with the requirements of the Commissioner of Internal Revenue was made by the plaintiff in error without waiving its claim to the full deduction originally claimed. It further appears from the complaint that, in disobedience and disregard of the law and of the rules and regulations of the Treasury Department, the Commissioner of Internal Revenue dis- allowed the application for refund of the plaintiff in error in toto, which disallowance was communicated to the plaintiff In error December 29, 1913, by the defendant in error. Collector of Internal Revenue, the then collector having succeeded to the office of the Collector of Internal Revenue who had originally levied the tax in question. The complaint alleges that no part of the said tax has been refunded or paid back, and that the same is still due and unpaid. The questions propounded are: 1. Under the provisions of paragraph 38 of the Act of Con- gress entitled "An Act to provide revenue, equalize duties, and encourage the industries of the United States, and for other purposes," approved August 5, 1909 (36 Stat. L., p. 11, at p. 112), is a mining corporation, for the purpose of determining its net income for the basis of taxation, entitled to deduct from its gross income any amount whatever on accomit of depletion or exhaustion of ore bodies caused by its operations for the year for which the tax is assessed? 2. Is such a corporation under said act entitled in the ascer- tainment of its net income to a deduction against gross pro- ceeds from the mining and treatment of ores to the extent of the cost value of the ore in the ground before it was mined, ascertained in strict compliance with the rules and regulations of the Treasury Department of February 14, 1911 (Tr. Dec. 1675) ? 3. Where such a corporation claimed originally in its return of net income under said act a deduction for depreciation from exhaustion of ore for the year equal to the actual valua 1371 of the ore in the ground before it was mined, and having been denied any deduction whatever for exhaustion of ore, and having been assessed accordingly and having paid the resulting tax, made application pursuant to {Sections 3220 and 3226, lievised Statutes, for refund, during the pendency of which application said corporation was granted leave to amend and did amend its return of net income in strict accordance with the rules and regulations promulgated February 14, lyil (sees. 80 to 89, T. D. 1675), resulting in an amended return based upon cost as provided in said regulations and showing claimed deductions therefrom less than the corporation's net realiza- tions for the year from the ore actually mined, is such cor- poration entitled to an allowance of deductions and refund of taxes accordingly? 4. In what, if any, way is the right to such claimed deduc- tions affected by the fact that such corporation, in obedience to requirements imposed by the Commissioner of Internal Revenue at the time of liling its amended returns showing the cost value as of January 1, 1909, of the ores mined during the year, caused to be entered in its oiiicial books of account and printed in its annual report of that current year to all of its stockholders and to the public, a statement of the total amomit of ore exhaustions, multiplied by the unit cost per ton on its mining properties for that and all previous years! In the brief submitted for the Goldheld Consolidated Mines Company comisel frankly admit that if this court is to adhere to the principles laid down in Stratton's Independence v. Howbert (231 U. S., 399) and Von Baumbach, Collector, v. Sargent Land Company (242 U. S., 503), those cases are con- clusive against the contentions of the Mines Company in this proceeding. In view of the discussion of the nature of mining property in Stratton's Independence v. Howbert (supra), and the application of the principles therein laid down in the sub- sequent cases of Baltic Mining Company v. Stanton (240 U. S., 103), and Von Baumbach, Collector, v. Sargent Land Com- pany (supra), it is necessary to enter upon further considera- tion of the matters disposed of in those cases. We find no occasion to depart from the principles therein announced, or the rulings therein made. They have been reaffirmed in the case of United States v. Biwabik Mining Company, just de- cided. In this view it follows that the first and second ques- tions must be answered in the negative, and that it is unnec- essary to answer the tlurd and fourth questions. So ordered. (T. D. 2723.) Corporation Excise Tax Act of 1909— Decision of the Supreme Court — 1. Purpose of the Act. The legislative purpose was not to tax property as such or the mere conversion of property, but to tax the conduct of the business of corporations organized for profit by a meas- ure based upon the gainful returns from their business operations and property from the time the act took effect. 2. Treatment of Proceeds of Conversion of Capital Assets. The suggestion that the entire proceeds of the conversion of capital assets should be still treated as the same capital, 1272 changed only in form and containing iio element of income, although including an increment of value, is inconsistent with the general purpose of the act. 3. Meaning of "Income." "Income" imports, as used in the act, something entirely distinct from principal or capital either as a subject of taxa- tion or as a measure of the tax, conveying rather the idea of gain or increase arising from corporate activities. 4. Determination of Gain or Loss. In order to determine whether there has been gain or loss and the amount of the gain, if any, an amount must be withdrawn from the gross proceeds of sale sufficient to re- store the capital value that existed on December 31, 1908, notwithstanding any increment of value up to that time had not been entered upon the plaintiff's books of account. 5. Sales of Timber. The gain on a sale of timber acquired by a lumber manu- facturing company before January 1, 1909, and converted into money after that date is income within the meaning of the act, but only such portion of the gain as accrued subsequent to December 31, 1908, is taxable. 6. Judgment Affirmed. The judgment of the Circuit Court of Appeals is affirmed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court In the case of Emanuel J. Doyle, collector of internal revenue, V. Mitchell Brothers Company is published for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved Jime 4, 1918: L. S. ROWE, Acting Secretary of the Treasury. SUPREME COURT OF THE UNITED STATES. No. 492. OCTOBER TERM, 1917. Emanuel J. Doyle, collector of internal revenue, petitioner, v. Mitchell Brothers Company. On writ of certiorari to the United States Circuit Court of Appeals for tlie Sixth Circuit. (May 20, 1918.) Mr. Justice Pitney delivered the opinion of the court : This was an action to recover from the collector additional taxes assessed against the respondent under the corporation excise-tax act of August 5, 1909 (ch. 6, 36 Stat. 11, 112, sec. 38), and paid under protest. The district court gave judgment for the plaintiff, which was affirmed by the Circuit Court of Appeals (225 Fed. Rep., 437; 235 Fed. Rep., 686), and the case comes here on certiorari. It was submitted at the same time with several other cases decided this day arising under the same act. 1273 The facts are as follows: Plaintiff is a lumber manufactur- ing corporation which operates its own mills, manufactures into lumber therein its own stumpage, sells the lumber in the market, and from these sales and sales of various by-products makes its profits, declares its dividends, and creates its sur- plus. It sells its stumpage lands, so called, after the timber is cut and removed. Its sole business is as described; it is not a real estate trading corporation. Plaintiff acquired certain timberlands at its organization in 1903 and paid for them at a valuation approximately equivalent to $30 per acre. Owing to increases in the market price of stumpage the market value of the timberland, on December 31, 1908, had become approxi- mately $40 per acre.* The company made no entry upon its books representing this increase, but each year entered as a profit the difference between the original cost of the timber cut and the sums received for the manufactured product, less the cost of manufacture. After the passage of the excise-tax act, and preparatory to making a return of income for the year 1909, the company revalued its timber stumpage as of December 31, 1908, at approximately $40 per acre. The good faith and accuracy of this valuation are not in question, but the figures representing it never were entered in the corporate books. Under the act the company made a return for each of the years 1909, 1910, 1911 and 1912, and in each instance deducted from its gross receipts the market value, as of December 31, 1908, of the stumpage cut and converted during the year covered by the tax. There appears to have been no change in its market value during these years. The Commissioner of Internal Revenue having allowed a deduction of the cost of the timber in 1903 and refused to allow the difference between that cost and the market value of the timber on December 31, 1908, the question is whether this difference (made the basis of the additional taxes) was income for the y^ars in which it was converted into money, within the meaning of the act. Other items are involved in the case, arising from the sale of certain stump lands, certain by-products, and a parcel of real estate, but they raise no different question from that which arises upon the valuation of the stumpage, and need not be further mentioned. The act became effective January 1, 1909, and provided for the annual payment by every domestic corporation "organized for profit and having a capital stock represented by shares" of an excise tax "equivalent to one per centum upon the entire net income over and above five thousand dollars re- ceived by it from all sources during such year," with excep- tions not now material. It is declared that such net income should be ascertained by deducting from the gross mcome received within the year from all sources the expenses paid within the year out of income in the maintenance and opera- tion of business and property, including rentals and the like; losses sustained within the year and not compensated by in- surance or otherwise, including a reasonable allowance for depreciation of property; interest paid within the year to a limited extent; taxes; and amounts received within the year as dividends upon stock of other corporations subject to the same tax. In the case of a corporation organized under the •The valuations were based upon the Qu^'^tity of standing tlm ber, 1274 ber? at certain prices per thousand feet for the different varieties. ^ ayproxiniate acreage equivalent is employed for convenience. laws of a foreign country, the net income was to be ascer- tained by taking into account the gross income received within the year "from business transacted and capital invested within the United States and any of its Territories, Alaska and the District of Columbia," with deductions for expenses of main- tenance and operation, business losses, interest and taxes, all referable to that portion of its business transacted and capital invested within the United States, etc. An examination of these and other provisions of the act makes it plain that the legislative purpose was not to tax property as «uch, or the mere conversion of property, but to tax the conduct of the business of corporations organized for profit by a measure based upon the gainful returns from their business operations and property from the time the act took effect. As was pointed out in Flint v. Stone Tracy Co. (220 U. S., 107, 145), the tax was imposed "not upon the franchises of the corporation irrespective of their use in business, nor upon the property of the corporation, but upon the doing of corporate or insurance business and with respect to the carry- ing on thereof"; an exposition that has been consistently ad- hered to. McCoach v. Minehill R. R. Co. (228 U. S., 295, 300) ; United States v. Whitridge (231 U. S., 144, 147); Anderson v. Forty-two Broadway (239 U. S., 69, 72). When we come to apply the act to gains acquired through an increase in the value of capital assets acquired before and converted into money after the taking effect of the act, ques- tions of difficulty are encountered. The suggestion that the entire proceeds of the conversion should be still treated as the same capital, changed only in form and containing no element of income, although including an increment of value, we reject at once as inconsistent with the general purpose of the act. Selling for profit is too familiar a business transaction to permit us to suppose that it was intended to be omitted from consideration in an act for taxing the doing of business in corporate form upon the basis of the income received "from all sources." Starting from this point, the learned Solicitor General has submitted an elaborate argument in behalf of the Government, based in part upon theoretical definitions of "capital," "in- come," "profits," etc., and in part upon expressions quoted from our opinions in Flint v. Stone Tracy Company (220 U. S., 107, 147), and Anderson v. Forty-two Broadway (239 U. S., 69, 72), with the object of showing that a conversion of capi- tal into money always produces income, and that for the purposes of the present case the words "gross income" are equivalent to "gross receipts"; the insistence being that the entire proceeds of a conversion of capital assets should be treated as gross income, and that by deducting the mere cost of such assets we arrive at net income. The cases referred to throw little light upon the present matter, and the expres- sions quoted from the opinions were employed by us with reference to questions wholly remote from any that is here presented. The formula that the entire receipts derived from a con- version of capital assets after deducting cost value must be treated as net income, so far as it is applied to a conversion of assets acquired before the act took effect and so as to tax as income any increased value that accrued before that date, finds no support in either the letter or the spirit of the act, and brings the former into incongruity with the latter. If the gross receipts upon such a conversion are to be treated as 1275 gross income, what authority have we for deducting either the cost or the previous market value of the assets converted in order to arrive at net income? The deductions specifically authorized are only such as expenses of maintenance and operation of the business and property, rentals, uncompen- sated losses, depreciation, interest and taxes. There is no express provision that even allows a merchant to deduct the cost of the goods that he sells. Yet it is plain, we think, that by the true intent and mean- ing of the act the entire proceeds of a mere conversion of capi- tal assets were not to be treated as income. Whatever diffi- culty there may be about a precise and scientific definition of "income," it imports, as used here, something entirely dis- tinct from principal or capital either as a subject of taxation or as a measure of the tax; conveying rather the idea of gain or increase arising from corporate activities. As was said in Stratton's Independence v. Howbert (231 U. S., 399, 415) : "Income may be defined as the gain derived from capital, from labor, or from both combined." Understanding the term in this natural and obvious sense, it can not be said that a conversion of capital assets invariably produces income. If sold at less than cost, it produces rather loss or outgo. Nevertheless, in many if not in most cases there results a gain that properly may be accounted as a part of the "gross income" received "from all soui'ces," and by applying to this the authorized deductions we arrive at "net income." In order to determine whether there has been gain or loss, and the amount of the gain, if any, we must with- draw from the gross proceeds an amount sufficient to restore the capital value that existed at the commencement of the period under consideration. This has been recognized from the beginning by the admin- istrative officers of the Government. Shortly after the pas- sage of the act, and before the time (March 1, 1910) for mak- ing the first returns of income, the Commissioner of Internal Revenue, with the approval of the Secretary of the Treasury, promulgated Regulations No. 31, under date December 3, 1909, for the guidance of collectors and other subordinate offi- cers in the performance of their duties under the act. These prescribed, with respect to manufacturing companies, that gross income should consist of the difference between the price received for the goods as sold and the cost of such goods as manufactured; cost to be "ascertained by an addition of a charge to the account of the cost of goods as manufactured during the year of the sum of the inventory at beginning of the year and a credit to the account of the sum of the inven- tory at the end of the year." In the case of mercantile com- panies, gross income was to be the "amount ascertamed through inventory, or its equivalent, which shows the differ- ence between the price received for goods sold and the cost of goods purchased during the year, with an addition of a charge to the account of the sum of the inventory at begin- ning of the year and a credit to the account of the sum of the inventory at the end of the year." And as to miscellaneous corporations, gross income was to be "the gross revenue de- rived from the operation and management of the business and property of the corporation," with all income derived from other sources. The matter of income arising from a profitable gale of capital assets was dealt with specifically in such a way as to limit the tax to income arising after the effective date of the act. This was done by adopting the rule that an ad- 1276 vance in value arising during a period of years should be so adjusted that only so much as property was attributable to the time subsequent to January 1, 1909 (December 31, 1908, would have been more precise), should be subjected to the tax.* Subsequent Treasury regulations, promulgated from time to time (T. D. 1606, March 29, 1910, paragraphs 40, 71, 76; T. D. 1675, February 14, 1911, paragraphs 37, 55, 75; T. D. 1742, December 15, 1911, paragraphs 43, 62, 86, 91), adhered to the same rule with respect to lands bought prior to Janu- ary 1, 1909, and sold during a subsequent year, prescribing, however, that the profits, when not otherwise accurately de- terminable, should be prorated according to the time elapsed before and after the act took effect; and gave to it an appli- cation especially pertinent here, one of the regulations reading: The mere removal of timber by onttinj? from timber lanfli=!, unless the timber Is otherwise disposed of through sales or plant opera- tions, is considered simply a change in form of assets. If said timber is disposed of through sales or otherwise, it is to be Recounted for in accordance with regulations governing disposi- tion of capital and other assets. In our opinion these regulations correctly interpret the act in its application to the facts of the present case. When the Oct took effect, plaintiff's timber lands, with whatever value they then possessed, were a part of its capital assets, and a subsequent change of form by conversion into money did not change the essence. Their increased value since purchase, as that value stood on December 31, 1908, was not in any proper sense the result of the operation and management of the business or property of the corporation while the act was in force. Nor is the result altered by the mere fact that the increment of value had not been entered upon plaintiff's books of account. Such books are no more than evidential, being neither indispensable nor conclusive. The decision must rest upon the actual facts, which in the present case are not in dispute. The plaintiff, in making up its income tax returns for the years 1909, 1910, 1911 and 1912, deducted from its gross re- ceipts the admittedly accurate valuation as of December 31, 1908, of the stumpage cut and converted during the year cov- ered by the tax. There having been no change in market values during these years, the deduction did but restore to the capital in money that which had been withdrawn in stumpage cut, leaving the aggregate of capital neither increased nor decreased, and leaving the residue of the gross receipts to represent the gain realized by the conversion, so far as that grain arose while the act was in effect. This was in accord- ance with the true intent and meaning of the act. It may be observed that it is a mere question of methods, not affecting the result, whether the amount necessary to be withdrawn in order to preserve capital intact should be de- ♦TJxtract from Treasury Regulations No. 31, Issued December 3, 1909: Sale of Capital Assets. — Tn ascertaining income derived from the sale of capital assets If the assets were acquired subsequent to January 1, 1909, the difference between the selling price and the buying price shall constitute an item of gross income to be added to or subtracted from gross Income according to whether the selling price was greater or less than the buying price. If the capital assets were acquired prior to January 1, 1909, the amount of increment or depreciation representing the diflFerence between the selling and buying price Is to be adjusted so as to fairly determine tbe proportion of the loss or gain arising subse- quent to January 1, 1909, and which proportion shall be deducted from or added to the gross income for the year In which the sale was made. 1277 ducted from gross receipts in the process of ascertaining gross income or should be deducted from gross income in the form of a depreciation account in the process of determining net income. In either case the object is to distinguish capital previously existing from income taxable under the act. There is only a superficial analogy between this case and the case of an allowance claimed for depreciation of a mining property through the removal of minerals, since we have held that owing to the peculiar nature of mining property its partial exhaustion attributable to the removal of ores can not be regarded as depreciation within the meaning of the act. Von Baumbach v. Sargent Land Company (243 U. S., 503, 520, 524); United States v. Biwabik Mining Company, this day decided; Goldfield Consolidated Mines Company v. Scott, this day decided. It should be added that in this case no question is raised as to whether, in apportioning the profits derived from a disposition of capital assets acquired before and converted after the act took effect, the division should be pro rata, ac- cording to the time elapsed, or should be based upon an inven- tory taken as of December 31, 1908. PlaintilTs, in accordance with Treasury Regulations No. 31, T. D. 1578, January 4, 1910, and T. D. 1588, January 24, 1910, adopted the latter method, and the Government makes no contention as to the accuracy of the result thereby reached, under the stipulated facts, if our construction of the act be correct. Judgment affirmed. (T. D. 2724.) Corporation excise tax act of 1909 — Decision of the Supreme Court— l.The Act of March 2, 1867, Distinguished. The act of March 2, 1867, with certain exceptions, taxed only such gains or profits as might be realized from a busi- ness transaction begun and completed during the preceding year, but the language of the act of 1909 is different in material particulars. — Gray v. Darlington (15 Wall., 63), which construed the former act, is accordingly not con- trolling. 2. Construction of the Act. The act measured the tax by the income received within the year for which the assessment was levied, whether it accrued within that year or in some preceding year while the act was in effect; but it excluded all income that accrued prior to January 1, 1909, although afterwards received while the act was in effect. B. Computation of Gain. The sale of stock resulted in a gain or profit to the extent of the difference between the buying and selling prices, there being no merit in the contention that interest^ should be added to the purchase price in order to ascertain its cost, and so much of the profits as may be deemed to have ac- crued subsequent to December 31, 1908, must be treated as a part of the gross income of the respondent. 4. Determination of Value of Capital Assets on December 31, 1908. Whether the determination of the value of the capital assets on December 31, 1908, should be made by taking an 1278 L inventory upon the basis of market values then existing, or whether the entire increment accruing between the time of acquiring and the time of disposing of -the assets should be prorated as if it had arisen through a series of gradual and imperceptible augmentations, is a matter of detail, to be settled according to the best evidence abtainab^e and in accordance with valid departmental regulations. 5. Judgment Reversed. The judgment of the Circuit Court of Appeals is reversed and that of the District Court is affirmed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court in the case of S. A. Hays, collector of internal revenue, v. The Gauley Mountain Coal Company is published for the informa* tion of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved June 4, 1918: L. S. ROWE, Acting Secretary of the Treasury. SUPREME COURT OF THE UNITED STATES. No. 327. OCTOBER TERM, 1917. 5. A. Hays, collector of internal revenue for the district of West Virginia, petitioner, v. The Gauley Mountain Coal Company. On writ of certiorari to the United States Circuit Court of Appeals for the Fourth Circuit. (May 20, 1918.) Mr. Justice Pitney delivered the opinion of the court: Suit by the Gauley Mountain Coal Company against the collector to recover taxes alleged to have been unlawfully col- lected under corporation excise-tax act of August 5, 1909 (ch. 6, 36 Stat., 11, 112, sec. 38). The district court gave judgment in favor of defendant, which was reversed by the Circuit Court of Appeals (230 Fed. Rep., 110), whereupon a writ of certiorari was allowed. The case was submitted, together with several other cases decided this day, arising under the same act. The agreed facts are in substance as follows: The com- pany is a mining corporation organized under the laws of the State of West Virginia. The business of trading in stocks is not included among its corporate powers, nor does it appear that, with a single exception, it ever bought or sold any. On December 9, 1902, it purchased certain shares of another mining corporation for $800,000, and sold them October 16, 1911, for $1,010,000, this sum being less by $214,933.33 than the purchase price plus interest at 6 per cent, but greater by $210,000 than cost ignoring interest. The Commissioner of Internal Revenue held that a proportion of the $210,000 rep- resented by the ratio of the 1,019 days that elapsed between January 1, 1909, when the corporation excise-tax act became effective, and October 16, 1911, the date of the sale, to the 3,233 days that elapsed between the date of purchase and the 1279 date of sale, constituted income of the corporation for the year 1911 within the meaning of the act. The apportioned simi, $66,189.30, reduced to $52,506 by certain deductions not now in question, was made the basis of an additional assess- ment at 1 per cent upon the latter sum; and this assessment, having been collected by duress, formed the subject of the present suit. The decision of the Circuit Court of Appeals, and the prin- cipal contentions made by respondent in support of it, are based upon the decision of this court in Gray v. Darlington (15 Wall., 63). That case arose under the act of Congress of March 2, 1867 (14 Stat., 477, ch. 169, sec. 13), which pro- vided that a certain tax should be levied, collected and paid annually upon the amount over $1,000 of the gains, profits and income of every person, declaring that "the tax herein provided for shall be assessed, collected and paid upon the gains, profits and income for the year ending the thirty-first of December next preceding the time for levying, collecting and paying said tax." There was this further provision: "That, in estimating the gains, profits and income of any person, there shall be included all income derived from interest upon notes, bonds and other securities of the United States; profits realized within the year from sales of real estate purchased within the year or within two years previous to the year for which income is estimated. . . . and all other gains, profits and income derived from any sources whatever," with an exception that need not be stated. It appeared that plain- tiff acquired certain United States bonds in the year 1865 and sold them in 1869 at an advance of $20,000 over their cost, and was taxed upon this amount as gains, profits and income for the latter year. This court held that by the true construction of the act, except, as to gains and profits from trade and commerce and sales of real property, the statute only applied to such gains, profits and income as were strictly acquisitions made during the year preceding that in which the assessment was levied and collected. We do not regard the decision as controlling, because the language of the act now under con- sideration is different in material particulars. As pointed out in Doyle, collector, v. Mitchell Brothers Company, this day decided, ante, p. — , it imposes annually a special excise tax with respect to the carrying on or doing business by the cor- poration "equivalent to one per centum upon the entire net income over and above five thousand dollars received by it from all sources during such year," to be ascertained by tak- ing gross income and applying certain exceptions and deduc- tions. "Gains, profits and income for the year ending the thirty-first day of December next preceding" (act of 1867) conveys a different meaning from "the entire net income . . . received by it . . . during such year" (act of 1909). The former expression, as this court held (15 Wall., 65), denoted "such gains or profits as may be realized from a business transac- tion begun and completed during the preceding year,'* with the exceptions already mentioned. The expression "income received during such year," employed in the act of 1909, looks to the time of realization rather than to the period of accrue- ment, except as the taking effect of the act on a specified date (January 1, 1909) excludes income that accrued before that date. There are other differences upon which we need not dwell. As we construe the latter act, it measured the tax by the income received within the year for which the assessment 1380 was levied, whether it accrued within that year or in some preceding year while the act was in elFect; but it excluded all income that accrued prior to January 1, 1909, although afterwards received while the act was in effect. This brings us to consider whether the proceeds of the sale of stock by respondent in October, 1911, included anything, and if so, how much, of "income" accruing on or after Janu- ary 1, 1909, as the term "income" is employed in the act. That the sale resulted in a gain or profit to the extent of $210,000, the difference between the buying and selling prices, is not to be doubted, for there is no merit in the contention that interest should be added to the purchase price in order to ascertain its cost. The money that went into the purchase was not loaned at interest; on the contrary, by the very fact of the purchase it was placed where it could not earn interest for the respondent in the ordinary sense, and the gain rep- resented by the increase of selling price over cost price must be regarded as a substitute for whatever return some other form of investment might have yielded. It results that so much of the $210,000 of profits as may be deemed to have accrued subsequent to December 31, 1908, must be treated as a part of the "gross income" of respondent. For it is the simple case of a conversion of capital assets acquired before and turned into money after the taking effect of the act; and, as we have shown in Doyle, collector, v. Mitchell Brothers Company, this day decided, since a conversion of capital often results in gain, the general purpose of the act of 1909 to measure the tax by the increase arising from corporate activities together with the income from invested property leads to the inference that that portion of the gross proceeds which represents gain or increase acquired after the taking effect of the act must be regarded as "gross income"; and to this end it must be distinguished from that portion which represents a return of the capital value existing before. In order to do this, it is necessary to ascertain what was the value of the capital assets on December 31, 1908. Whether this should be done by taking an inventory upon the basis of market values then existing, or whether the entire increment accruing between the time of acquiring and the time of dis- posing of the assets should be prorated as if it had arisen through a series of gradual and imperceptible augmentations, is a matter of detail, to be settled according to the best evi- dence obtainable, and in accordance with valid departmental regulations. Treasury Regulations No. 31, December 3, 1909, provided for inventories at the beginning and end of each year with respect to manufacturing and mercantile companies; and with regard to a sale of capital assets acquired prior to January 1, 1909, and sold thereafter, required that the amount of increment or depreciation representing the difference be- tween the selling and buying prices should be adjusted so as fairly to determine the proportion of the loss or gain arising subsequent to the date mentioned; but without prescribing any particular method of doing this. Subsequent rulings re- quired that sales of stocks and bonds should be regarded as sales of capital assets and accounted for accordingly under Regulations No. 31, and, while still requiring inventories, re- sorted to the prorating method with respect to real estate, ap- parently on the ground that increases and decreases in the value of this class of property during particular periods could not be accurately determined. (T. D. 106, March 29, 1910, paragraphs 37, 50, 71; T. D. 1675, February 14, 1911, para- 1281 graphs 36, 48, 55, 69; T. D. 1743, December 15, 1911, para- graphs 42, 55, 62, 86.) The present case was heard upon an agreed statement of facts which contains nothing from which the value of the stock at the time the act took effect may be deduced, other- wise than by the prorating method that was adopted; nor is any objection made by the respondent to the application of that method. Hence there is no lawful ground for overthrow- ing the tax, and the district court did not err in rendering Judgment in favor of the collector. Judgment of the Circuit Court of Appeals reversed and that of the District Court aflirmed. (T. D. 2725.) Corporation Excise-Tax Act of 1909 — Decision of the Supreme Court — 1. Profit upon Sale of Corporate Stock. A railroad corporation purchasing stock in another cor- poration for investment prior to January 1, 1909, is taxable with respect to so much of the profit upon a sale of the stock as accrued after December 31, 1908. 2. Determination of Value of Stock on December 31, 1908. The market value of the stock on December 31, 1908, may be determined by an inventory taken as of that date, and the stipulated fact of the market value of the stock on that date may be accepted as supplying the lack of an inventory. 3. Judgment Affirmed. The judgment of the Circuit Court of Appeals is affirmed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court in the case of the United States of America v. The Cleveland, Cincinnati, Chicago and St. Louis Railway Company is pub- lished for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved June 4, 1918: L. S. ROWE, Acting Secretary of the Treasury. SUPREME COURT OF THE UNITED STATES. No. 593. OCTOBER TERM, 1917. United States of America, petitioner, v. Cleveland, Cincinnati, Chicago and St. Louis Railway Company. On writ of certiorari to the United States Circuit Court of Appeals for the Sixth Circuit. (May 20, 1918.) Mr. Justice Pitney delivered the opinion of the court: In January, 1900, the respondent purchased 30,000 shares of stock of the Chesapeake and Ohio Railway Company for $981,- 427.92, and sold them January 28, 1909, for $1,795,719— a profit 1282 of over $814,000. It included no portion of this profit in its return for the year 1909 under the corporation excise-tax act of August 5, 1909 (ch. 6, 36 Stat., 11, 112, sec. 38), and the United States brought this suit to recover the tax of 1 per cent thereon. The district court directed a verdict in favor of plaintiff. Upon review the circuit court of appeals held the proceeds of sale of the stock could not be considered as income under the act except to the extent by which they exceeded the market value of the stock on December 31, 1908, ascertained to be $57 per share. It therefore reversed the judgment, and remanded the case with instruction to enter a new judgment to include a tax on this account only upon the balance of the selling price above $57 per share or $1,710,000 in all. (243 Fed., Rep. 18.) A writ of certiorari was then allowed. For reasons sufficiently stated in Doyle, collector, v. Mitchell Brothers Company and Hays, collector, v. Gauley Mountain Coal Company, this day decided, ante, pp. — , — , we concur in the view that defendant was not taxable except with respect to so much of the profit upon the stock as accrued after De- cember 31, 1908. Just how this part is to be separated from that which previously accrued is a matter of some nicety, as we have shown in the Hays case. The Circuit Court of Ap- peals adopted the theory of an inventory taken as of the time the act went into effect; and although the assets here under consideration were not acquired for the purpose of sale in the manner of merchandise, but were bought for investment, and hence were not inventoried on December 31, 1908, it accepted the stipulated fact that the stock had regular market value of $57 per share on that date as supplying the lack of an inventory. This result accords with the views we have ex- pressed in the cases referred to. Judgment affirmed. Mr. Justice Holmes took no part in the consideration or decision of this case. (T. D. 2726.) Income Tax Act of October 3, 1913 — ^Decision of the Supreme Court — 1. Effect of Sixteenth Amendment. The sixteenth amendment to the Constitution of the United States does not extend the taxing power to new or excepted subjects, but merely removes all occasion which otherwise might exist for an apportionment among the States of taxes laid on income, whether it be derived from one source or another. 2. Nature of Tax. The tax is not laid on articles in course of exportation or on anything which inherently or by the usages of commerce is embraced in exportation or any of its processes, but on the contrary is a general tax. 3. Net Income from Exportation Taxable. The net income from the venture of exportation when completed, that is to say, after the exportation and sale are fully consummated, is subject to taxation under general laws. 4. Judgment Affirmed. The judgment of the District Court is affirmed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court in the case of William E. Peck and Company (Inc.) v. John Z. Lowe, Jr., collector of internal revenue, is published, for the information of internal revenue officers and others concerned: DANIEL C. ROPER, Commissioner of Internal Revenue. Approved June 4, 1918: L. S. ROWE, Acting Secretary of the Treasury. SUPREME COURT OF THE UNITED STATES. No. 234. OCTOBER TERM, 1917. William E. Peck and Company (Inc.), plaintiff in error, v. John Z. Lowe, Jr., collector, etc. In Error to the District Court of the United States for the Southern District of New York. (May 20, 1918.) Mr. Justice Van Devanter delivered the opinion of the court : This was an action to recover a tax paid under protest and alleged to have been imposed contrary to the constitutional provision (art. 1, sec. 9, cl. 5) that "No tax or duty shall be laid on articles exported from any State." The judgment below was for the defendant. (234 Fed., 135.) The plaintiff is a domestic corporation chiefly engaged in buying goods in the several States, shipping them to foreign countries, and there selling them. In 1914 its net income from this business was $30,173.66 and from other sources $12,436.24. An income tax for that year, computed on the aggregate of these sums, was assessed against it and paid under compul- sion. It is conceded that so much of the tax as was based on the income from other sources was valid, and the contro- versy is over so much of it as was attributable to the income from shipping goods to foreign countries and there selling them. The tax was levied under the act of October 3, 1913 (c. 16, Sec. II., 38 Stat., 166, 172), which provided for annually sub- jecting every domestic corporation to the payment of a tax of a specified per centum of its "entire net income arising or accruing from all sources during the preceding calendar year." Certain fraternal and other corporations, as also income from certain enumerated sources, were specifically excepted, but none of the exceptions included the plaintiff or any part of its income. So, tested merely by the terms of the act, the tax collected from the plaintiff was rightly computed on its total net income. But as the act obviously could not impose a tax forbidden by the Constitution, we proceed to consider whether the tax, or rather the part in question, was forbidden by the constitutional provision on which the plaintiff relies. The sixteenth amendment, although* referred to in argument, has no real bearing and may be put out of view. As pointed out in recent decisions, it does not extend the taxing power to new or excepted subjects, but merely removes all occasion, which otherwise might exist, for an apportionment among the States of taxes laid on income, whether it be derived from 1284 one source or another. Brushaber v. Union Pacific Railroad Company (240 U. S., 1, 17-19) ; Stanton v. Baltic Mining Com- pany (240 U. S., 103, 112-113). The Constitution broadly empowers Congress not only "to lay and collect taxes, duties, imposts and excises," but also "to regulate commerce with foreign nations." So, if the pro- hibitory clause invoked by the plaintiff be not in the way. Congress undoubtedly has power to lay and collect such a tax as is here in question. That clause says "No tax or duty shall be laid on articles exported from any State." Of course it qualifies and restricts the power to tax as broadly conferred. But to what extent? The decisions of this court answer that it excepts from the range of that power articles in course of exportation, Turpin v. Burgess (117 U. S., 504, 507); the act or occupation of exporting. Brown v. Maryland (12 Wheat., 419, 445) ; bills of lading for articles being exported, Fair- banks V. United States (181 U. S., 283) ; charter parties for the carriage of cargoes from State to foreign ports. United States V. Hvoslef (237 U. S., 1); and policies of marine insur- ance on articles being exported — such insurance being uni- formly regarded as "an integral part of the exportation" and the policy as "one of the ordinary shipping documents," Thames and Mersey Ins. Company v. United States, 237 U. S., 19. In short, the court has interpreted the clause as meaning that exportation must be free from taxation, and therefore as requiring "not simply an omission of a tax upon the articles exported, but also a freedom from any tax which directly burdens the exportation." Fairbanks v. United States, supra, pages 292-293. And the court has indicated that where the tax is not laid on the articles themselves while in course of exportation the true test of its validity is whether it "so directly and closely" bears on the "process of exporting" as to be in substance a tax on the exportation. Thames and Mersey Ins. Company v. United States, supra, page 25. In this view it has been held that the clause does not condemn or invalidate charges or taxes, not laid on property while being exported, merely because they affect exportation indirectly or remotely. Thus a charge for stamps which each package of manufac- tured tobacco intended for export was required to bear before removal from the factory was upheld in Pace v. Burgess, 92 U. S., 372, and Turpin v. Burgess, 117 U. S., 504; and the application of a manufacturing tax on all filled cheese to cheese manufactured under contract for export, and actually exported, was upheld in Cornell v. Coyne, 192 U. S., 418. In that case it was said, page 427: "The true construction of the constitutional provision is that no burden by way of tax or duty can be cast upon the exportation of articles, and does not mean that articles exported are relieved from the prior ordinary burdens of taxation which rest upon all property similarly situated. The exemption attaches to the export and not to the article before its exportation. While fully assenting and adhering to the interpretation which has been put on the clause in giving effect to its spirit as well as its letter, we are of opinion that to broaden that interpretation would be to depart from both the spirit and letter. The tax in question is unlike any of those heretofore con- demned. It is not laid on articles in course of exportation or on anything which inherently or by the usages of commerce is embraced in exportation or any of its processes. On the con- trary, it is an income tax laid generally on net incomes. And 1285 while it can not be applied to any income which Congress has no power to tax (see Stanton v. Baltic Mining Company, supra, p. 113), it is both nominally and actually a general tax. It is not laid on income from exportation because of its source, or in a discriminative way, but just as it is laid on other income. The words of the act are "net income aris- ing or accruing from all sources." There is no discrimination. At most, exportation is affected only indirectly and remotely. The tax is levied after exportation is completed, after all ex- penses are paid and losses adjusted, and after the recipient of the income is free to use it as he chooses. Thus what is taxed — the net income — is as far removed from exportation as are articles intended for export before the exportation begins. If articles manufactured and intended for export are subject to taxation under general laws up to the time they are put in course of exportation, as we have seen they are, the con- clusion is unavoidable that the net income from the venture when completed, that is to say, after the exportation and sale are fully consummated, is likewise subject to taxation under general laws. In that respect the status of the income is not different from that of the exported articles prior to the exportation. For these reasons we hold that the objection urged against the tax is not well grounded. Judgment affirmed. (T. D. 2729.) Income Tax Act of October 3, 1913— Decision of the Supreme Court— 1. Taxable Income. Where the capital assets of a corporation increased in value prior to March 1, 1913, and a single and final divi- dend was made in liquidation of the entire assets in 1914, without further appreciation or addition to the assets hav- ing occurred, no part of the dividend received by a stock- holder is taxable under the act of October 3, 1913.— Collector V. Hubbard (12 Wall., 1), and Bailey v. Railroad Co. (22 Wall., 604; 106 U. S., 109) discussed. 2. Judgment Affirmed. The judgment of the Circuit Court of Appeals is affirmed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court in the case of E. J. Lynch, as collector of internal revenue, v. Henry Turrish, is published for the information of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved June 11, 1918: L. S. ROWE, Acting Secretary of the Treasury. 1286 SUPREME COURT OF THE UNITED STATES. NO. 421. OCTOBER TERM, 1917. E. J. Lynch, Collector of Internal Revenue for the District of Minnesota, petitioner, v. Henry Turrish. On Writ of Certiorari to the United States Circuit Court of Appeals for the Eighth Circuit. [June 3, 1918.] Mr. Justice McKenna delivered the opinion of the court: Suit to recover an income tax, paid under protest, assessed under the act of October 3, 1913, 38 Stat. 166. The facts, as submitted by demurrer, are these: Respond- ent, Turrish, who was plaintiff in the trial court, made a re- turn of his income for the calendar year 1914 which showed that he had no net income for that year; afterwards the Commissioner of Internal Revenue made a supplemental assessment showing that he had received a net income of $32,712.08, which, because of specific deductions and exemp- tions, resulted in no normal tax, but as the net income ex- ceeded the sum of $20,000 the commissioner assessed an addi- tional or super tax of one per cent upon the excess, resulting in a tax of $127.12, which was sought to be recovered. The re-asssessment was based upon certain sums received by the plaintiff in the year 1914 as distributions from corpora- tions subject to the income-tax law and held by the com- missioner to be income derived from dividends received by the plaintiff on stock of domestic corporations; of which the sum of $79,975, received as a distribution from the Payette Lumber & Manufacturing Co., and without which no tax could have been levied against the plaintiff is here in dispute. Prior to March 1, 1913, and continuously thereafter until the surrender of his stock as hereinafter mentioned, plaintiff was a stockholder in the Payette Co., which was organized in the year 1903 with power to buy, hold, and sell timber- lands, and in fact never engaged in any other business than this except minor businesses incidental to it. Immediately after its organization this company began to invest in timber- lands, and prior to March 1, 1913, had thus invested approxi- mately $1,375,000. On March 1, 1913, the value of its assets was not less than $3,000,000, of which sum the value of the timberlands was not less than $2,875,000. The increase was due to the gradual rise in the market value of the lands. At that date the value of Turrish's stock was twice its par value, pr $159,950, and about that time he and all the other stockholders gave an option to sell their stock for twice its par value. The holders of the option formed another company, called the Boise-Payette Lumber Co., and transferred the options to it. The options having been extended to December 31, 1913, the new company informed the Payette Co. and its stockholders shortly before this date that instead of exercising the option it preferred and proposed to purchase all of the assets of the Payette Co., paying to that company such a purchase price that there would be available for distribution to its stockholders twice the par value of their stock. The stock- holders by resolution authorized this sale, and, pursuant to this and a resolution of the directors, the Payette Co. trans- ferred to the new company all of its assets, property, and franchises, and upon the completion of the transaction found itself with no assets or property, except cash to the amount 1287 of double the par value of its stock which had been paid to it by the new company, and with no debt, liabilities, or obli- gations except those which the new company had assumed. The cash was distributed to the stockholders on the surrender of their certificates of stock, and the company went out of business. In this way, upon the surrender of his shares, Turrish received $159,950, being double their par value. The Commissioner of Internal Revenue considered that of this sum one -half was not taxable, being tlie liquidation of the par value of Turrish's stock, but that the other half was income for the year 1914 and taxable under the act of 1913. The question in the case is thus indicated. The district court took a different view from that of the Commissioner of Internal Revenue and therefore overruled the demurrer to Turrish's complaint and entered judgment for him for the sum prayed, which judgment was affirmed by the Circuit Court of Appeals for the Eighth Circuit. (236 Fed., 653.) The point in the case seems a short one. It, however, has provoked much discussion on not only the legal but the economic distinction between capital and income and by what processes and at what point of time the former produces or becomes the latter. And this in resolution of a statute which concerns the activities of men and intended, it might be sup- posed, to be without perplexities and readily solvable by the offhand conceptions of those to whom it was addressed. The provisions of the act, so far as material to be noticed, are the following: That there is assessed "upon the entire net income arising or accruing from all sources in the pre- ceding calendar year to every * ♦ * person residing in the United States * ♦ ♦ a tax of one per centum per annum upon such income * * * » (Par. A, subdiv. 1.) In addition to that tax, which is denominated the normal income tax, it is provided that there shall be levied "upon the net income of every individual an additional tax * * * of one per centum per annum upon the amount by which the total net income exceeds" certain amounts, and the per- son subject to the tax is required to make a personal return of his total net income from all sources under rules and regu- lations to be prescribed by the Commissioner of Internal Revenue. (Subdiv. 2.) By paragraph B it is provided that, subject to certain ex- emptions and deductions, "the net income of a taxable person shall include gains, profits, and income derived from salaries, wages, or compensation for personal service ♦ • * also from interest, rent, dividends, securities, or the transaction of any lawful business carried on for gain or profit, or gains or profits and income derived from any source whatever." After specifying tlie exemptions and deductions allowed, the law declares as follows: The said tax shall be computed upon the remainder of said net income of each pei'son subject thereto, accruing during each preceding calendar year ending December thirty-first: Provided, however, That for the year ending December thirty-first, nine- teen hundred and thirteen, said tax shall be computed on the net incotae accruing from March first Jo December thirty-first, nineteen hundred and thirteen, both dates inclusive ♦ ♦ ♦. (Par. D.) It will be observed, therefore, that the statute levies a normal tax and an additional tax upon net incomes, derived from whatever source, "arising or accruing" each preceding calendar year ending December 31, except that for the year 1288 ending December 31, 1913, the tax shall be computed on the net income accruing from March 1, 1913, to December 31, 1913. And in determining the application of the statute to Turrish we must keep in mind that on the admitted facts the dis- tribution received by him from the Payette Co. manifestly was a single and final dividend in liquidation of the entire assets and business of the company, a return to him of the value of his stock upon the surrender of his entire interest in the company, and at a price that represented its intrinsic value at and before March 1, 1913, when the act took effect. The district court and the Circuit Court of Appeals de- cided that the amount so distributed to Turrish was not in- come within the meaning of the statute, basing the decision on two propositions, as expressed in the opinion of the Circuit Court of Appeals, by Sanborn, circuit judge — (a) The amount was the realization of an investment made some years before, representing its gradual increase during those years, and which reached its height before the effective date of the law, that is, before March 1, 1913, and the mere change of form of. the property "as from real to personal property, or from stock to cash" was not income to its holders because the value of the property was the same after as before the change; (b) the timberlands were the property, capital, and capital assets of their legal and equitable owner and the enhancement of their value during a series of years "prior to the effective date of the income-tax law, although divided or distributed by dividend or otherwise subsequent to that date, does not become income, gains, or profits tax- able under such an act." For proposition "a" the court cited Collector v. Hubbard (12 Wall., 1); Bailey v. Railroad Company (22 Wall., 604, and the same case in 106 U. S., 109). For proposition "b" Gray v. Darlington (15 Wall., 63), was relied on. The Government opposes both contentions by an elaborate argument containing definitions of capital and income drawn from legal and economic sources and given breadth to cover a number of other cases submitted with this. The argument, in effect, makes any increase of value of property income, emerging as such and taxable at the moment of realization by sale or some act of separation, as by dividend declared or by distribution, as in the instant case. To sustain the argument these definitions are presented: 1. Capital is anything, material or otherwise, capable of owner- ship, viewed in its static condition at a moment of time, or the rights of ownership therein. 2. Income is the service or return rendered by capital during a period of time. ♦ ♦ ♦ 4. Net income ("profits") is the difference between income and outgo. ♦ ♦ * 7. In the actual production and distribution of capital there is a constant conversion of capital into income, and vice versa. 8. The attempt to conceal this conversion by treating "income" as the standard return from intact "capital" only leads to con- fusion of the value of capital with capital itself. From these definitions are deduced the following proposi- tions, which are said to be decisive of the problems in the cases: 1. Income being derived from the use of capital, the conversion or transfer of capital always produces income. 2. Mere appreciation of capital value does not produce "in- come," nor mere depreciutiou "outgo." 1289 3. Net Income Is the difference between actual "income" and actual "outgo." 4. Income is not confined to money income, but includes any- tliing capable of easy valuation in money. It will be observed that the breadth of definition and the breadth of application are necessary to the refutation of the reasoning of the Circuit Court of Appeals. There is direct antagonism, the court basing its reliance, it says, upon what it asserts is the common sense and understanding of the words of the law, and the exposition of like laws by the de- cisions of this court. The Government's resource is the dis- cussion of economists and the fact, concrete and practical, of wealth not only increased but come to actual hand. The instant case is an example. Turrish's stock doubled in value. He paid for it $79,975.00; he received $159,950.00. It requires a struggle to resist the influence of the fact, but we are aided and fortified by our own precedents and saved from such intricate and subtle discussion and an elaborate review of other cases cited in confirmation or opposition. In Collector v. Hubbard, supra, the distinction between a corporation and its stockholders was recognized and that the stockholder had no title for certain purposes to the earnings of the corporation, net or other, prior to a dividend being declared, but they might become capital by investment in permanent improvements and thereby increase the market value of the shares, "whether held by the original subscribers or by assignees." In other words, it was held that the in- vestments of the corporation were the investments of the stockholders; that is, the stockholders could have an interest, taxable under the act considered' though not identical w^ith the corporation. This was repeated in Bailey v. Railroad Co. (22 Wall., 604, 635, 636). The latter case came here again in 106 U. S., 109, and it was then declared that the purpose of an income tax law was to tax the income for the year that it accrued; in other words, no tax in contemplation of the law accrues upon some- thing except for the year in which that something — earnings, profits, gains, or income — accrues. In that case the subject of the tax was a scrip dividend, but the certificates did not show the year of the earnings and testimony as to the par- ticular year was admitted. The principle applies to the case at bar. If increase m value of the lands was income, it had its particular time and such time must have been within the time of the law to be subject to the law, that is, it must have been after March 1, 1913. But, according to the fact admitted, there was no increase after that date and therefore no increase subject to the law. There was continuity of value, not gain or increase. In the first proposition of the Court of Appeals we, therefore, concur. In support of its second proposition it adduced, as we have seen. Gray v. Darlington (15 Wall., 63). The case arose under the income tax law of 1867, which levied "upon the gains, profits, and income of every person, ♦ ♦ ♦ whether derived from any kind of property * * * or from any other source whatever * * * a tax of 5 per centum on the amount so derived over $1,000 * * * for the year ending the thirty -first of December next preceding the time for levying, collecting and paying said tax." Darlington, in 1865, being the owner of certain United States Treasury notes, exchanged them for United States bonds. In 1869 he sold the bonds at an advance of $20,000 1290 over the cost of the notes and upon this amount was levied a tax of 5 per centum as gains, profits, and income for that year. He paid the tax under protest and sued to recover, and prevailed. This court, by Mr. Justice Field, said: The question presented is wliether the advance in the value of the bonds, during this period of four years, over their cost, realized by their sale, was subject to taxation as gains, profits, or income of the plaintiff for the year in which the bonds were sold. The answer which should be given to this question does not, in our judgment, admit of any doubt. The advance in the value of property during a series of years can, in no just sense, be considered the gains, profits, or income of any one particular year of the series, although the entire amount of the advance be at one time turned into money by the sale of the property. The statute looks, with some exceptions, for subjects of taxation only to annual gains, profits and income. And again: The mere fact that property has advanced in value between the date of its acquisition and sale does not authorize the imposition of a tax on the amount of the advance. Mere advance in value in no sense constitutes the gains, profits, or income specified by the statute. It constitutes and can be treated merely as increase of capital. This case has not been since questioned or modifier' The Government feels the impediment of the case and at- tempts to confine its ruling to the exact letter of the act of March 2, 1867, and thereby distinguish that act from the act of 1913 and give to the latter something of retrospective effect. Opposed to this there is a presumption, resistless except against an intention imperatively clear. The Govern- ment, however, makes its view depend upon disputable differ- ences between certain words of the two acts. It urges that the act of 1913 makes the income taxed one "arismg or ac- cruing" in the preceding calendar year, while the act of 1867 makes the income one "derived." Granting that there is a shade of difference between the words, it cannot be granted that Congress made that shade a criterion of intention and committed the construction of its legislation to the disputes of purists. Besides, the contention of the Government does not reach the principle of Gray v. Darlington, which is that the gradual advance in the value of property during a series of years in no just sense can be ascribed to a particular year, not therefore as "arising or accruing," to meet the challenge of the words, in the last one of the years, as the Government contends, and taxable as income for that year or when turned into cash. Indeed, the case decides that such advance in value is not income at all, but merely increase of capital and not subject to a tax as income. We concur, therefore, in the second proposition of the Circuit Court of Appeals as well as in the first, and affirm the judgment. Mr. Justice Brandeis and Mr. Justice Clarke concur in the result. (T. D. 2730.) Income-Tax Act of October 3, 1913 — ^Decision of the Supreme Court — \ 1. Intention of the Act. It is the evident purpose of the act to refrain from tax- ing income that accrued prior to March 1, 1913, and to exclude from consideration in making computation of tax- i2di able income for a given year any income that accrued in the preceding taxable year. 2. Act of June 30, 1864, Compared and Distinguished. The income tax act of June 30, 1864, contains special language, different from the 1913 act, which distinguishes the case of Collector of Hubbard (12 Wall., 1), from the present case. 3. Taxability of Dividends from Subsidiary Corporation. Where a corporation is the owner of all the stock in a subsidiary company and the lessee of all its property, regularly maintaining possession, control, and management of all the subsidiary's money and other property, so that the subsidiary is a mere agent of the other corporation and is practically merged therewith, dividends of the sub- sidiary declared out of a surplus which accrued prior to March 1, 1913, are not taxable income of the parent cor- poration. 4. Effect of Decision Limited. This case turns on its peculiar facts. Pullman Car Co. v. Missouri Pacific Co. (115 U. S., 587) ; Peterson v. Chicago, Rock Island & Pacific Railway (206 U. S., 364), are dis- tinguishable. 5. Judgment Reversed. The judgment of the District Court is reversed, and the cause remanded for further proceedings. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court in the case of Southern Pacific Co. v. John Z. Lowe, Jr., aa Collector of Internal Revenue, is published for the information of internal -revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved June 11, 1918: L. S. ROWE, Acting Secretary of the Treasury. SUPREME COURT OF THE UNITED STATES. NO. 452. OCTOBER TERM, 1917. Southern Pacific Co., plaintiff in error, v. John Z. Lowe, Jr., United States Collector of Internal Revenue for the Second District of New York. In Error to the District Court of the United States for the Southern District of New York. [June 3, 1918.] Mr. Justice Pitney delivered the opinion of the court: This case presents a question arising under the Federal income-tax act of October 3, 1913 (Ch. 16, 38 Stat., 114, 166). Suit was brought by plaintiff-in-error against the collector to recover taxes assessed against it and paid under protest. There were two causes of action, of which only the second went to trial, it having been stipulated that the trial of the 1292 other might be postponed imtil the final determination of this one. So far as it is presented to us, the suit is an effort to recover a tax imposed upon certain dividends upon stock, in form received by the plaintiff from another corporation in the early part of the year 1914, and alleged by the plaintiff to have been paid out of a surplus accumulated not only prior to the effective date of the act but prior to the adoption of the sixteenth amendment to the Constitution ot the United States. The District Court directed a verdict and judgment in favor of the collector (238 Fed, Eep., 847), and the case comes here by direct writ of error under section 238, Judicial Code, because of the constitutional question. That our juris- diction was properly invoked is settled by Towne v. Eisner (245 U. S., 418, 425). The case was submitted at the same time with several other cases arising under the same act and decided this day, viz.: Lynch, Collector v. Turrish, and Lynch, Collector v. Hornby, and Peabody v. Eisner, Collector. The material facts are as follows: Prior to Januarv 1, 1913, and at all times material to the case, plaintiff, a cor- poration organized under the laws of the State of Kentucky, owned all the capital stock of the Central Pacific Railway Co., a corporation of the State of Utah, including the stock registered in the names of the directors.* This situation ex- isted continuously from the incorporation of the railway company in the year 1899. That company is the successor of the Central Pacific Railroad Co. and acquired all of its prop- erties, which constitute a part of a large system of railways owned or controlled by the Southern Pacific Co. The latter company, besides being sole stockholder, was in the actual physical possession of the railroads and all other assets of the railway company, and in charge of its operations, which were conducted in accordance with the terms of a lease made by the predecessor company to the Southern Pacific and as- sumed by the railway company, the effect of which was that the Southern Pacific should pay to the lessor company $10,000 per annum for organization expenses, should operate the rail- roads, branches, and leased lines belonging to the lessor, and account annually for the net earnings, and if these exceeded 6 per cent on the existing capital stock of the lessor the lessee should retain to itself one-half of the excess; ad- vances by the lessee for account of the lessor were to bear lawful interest, and the lessee was to be entitled at any time and from time to time to refund to itself its advances and interest out of any net earnings which might be in its hands. The provisions of the lease were observed by both corporations for bookkeeping purposes. The Southern Pacific acted as cashier and banker for the entire system; the Central Pacific kept no bank account, its earnings being deposited with the bank account of the Southern Pacific; and if the Central Pacific needed money for additions and betterments or for making up a deficit of current earnings the necessary funds were advanced by the Southern Pacific. As a result of these operations and of the conversion of certain capital assets of the Central Pacific Co., that company showed upon its books a large surplus accumulated prior to January 1, 1913, principally in the form of a debit against the Southern Pacific, which at the same time, as sole stockholder, was ♦There was another question, concerning a dividend paid by the Reward Oil Co., whose stock likewise was owned by the Southern Pacific Co., but the contention of plaintiff in error respecting this item has been abandoned. 1293 entitled to any and all dividends that might be declared, and being in control of the board of directors was able to and did control the dividend policy. The dividends in question were declared and paid during the first six months of the. year 1914 out of this surplus of the Central Pacific accumu- lated prior to January 1, 1913; but the payment was only constructive, being carried into effect by bookkeeping entries which simply reduced the apparent surplus of the Central Pacific and reduced the apparent indebtedness of the Southern Pacific to the Central Pacific by precisely the amount of the dividends. The question is whether the dividends received under these circumstances and in this manner by the Southern Pacific Co. were taxable as income of that company under the income tax act of 1913.t The act provides in section 2, paragraph A, subdivision 1 (38 Stat., 166), "that there shall be levied, assessed, collected, and paid annually upon the entire net income arising or ac- cruing from all sources in the preceding calendar year" to every person residing in the United States a tax of 1 per cent per annum, with exceptions not now material, by para- graph G (a) (p. 172), it is provided "that the normal tax hereinbefore imposed upon individuals [1 per cent] likewise shall be levied, assessed, and paid annually upon the entire net income arising or accruing from all sources during the preceding calendar year to every corporation " * * or- ganized in the United States," with other provisions not now material. It is provided in paragraph G (b), as to domestic corpora- tions, that such net income shall be ascertained by deducting from the gross amount of the income of the corporation (1) ordinary and necessary expenses paid within the year in the maintenance and operation of its business and properties, including rentals and the like; (2) losses sustained within the year and not compensated by insurance or otherwise, in- cluding a reasonable allowance for depreciation by use, wear and tear of property, if any, and in the case of mines a cer- tain allowance for depletion of ores and other natural de- posits; (3) interest accrued and paid within the year upon indebtedness of the corporation, within the prescribed limits; (4) National and State taxes paid. It will be observed that . moneys received as dividends upon the stock of other cor- porations are not deducted, as they are in computing the in- come of individuals for the purpose of the normal tax under this act (p. 167), and as they were in computing the income of a corporation under the excise tax act of August 5, 1909 (Ch. 6, 36 Stat., 11, 113, sec. 38). By paragraph G (c) the tax upon corporations is to be com- puted upon tJie entire net income accrued within each cal- endar year, but for the year 1913 only upon the net income accrued from March 1 to December 31, to be ascertained by taking five-sixths of the entire net income for the calendar year. The purpose to refrain from taxing income that accrued prior to March 1, 1913, and to exclude from consideration in making the computation any income that accrued in a pre- tln addition, n question was made to the District Court as to a special dividend declared by the Central I'aciflc out of the proceeds of sale of certain land on Long Island, taken in satis- faction of a debt and sold in December. 1913. As to this, how- ever, no argument is submitted by plaintiff in error, the facts are not clear, and we pass it without consideration. 1294 ceding calendar year, is made plain by the provision last referred to; indeed, the sixteenth amendment, under which for the first time Congress was authorized to tax income from property without apportioning the tax among the States according to population, received the approval of the requisite number of States only in February, 1913. (Pollock v. Farmers' Loan & Trust Co., 157 U. S., 429, 581; 158 U. S., 601, 637; Brushaber v. Union Pacific Railroad, 240 U. S., 1, 16.) We must reject in this case, as we have rejected in cases arising under the corporation excise tax act of 1909 (Doyle, collector, v. Mitchell Bros. Co., and Hays, collector, v. Gauley Mountain Coal Co., decided May 20, 1918), the broad conten- tion submitted in behalf of the Government that all receipts — eveiything that comes in — are income within the proper definition of the term "gross income," and that the entire proceeds of a conversion of capital assets, in whatever form and under whatever circumstances accomplished, should be treated as gross income. Certainly the term "income" has no broader meaning in the 1913 act than in that of 1909 (see Stratton's Independence v. Howbert, 231 U. S., 399, 416, 417), and for the present purpose we assume there is no difference in its meaning as used in the two acts. This being go, we are bound to consider accumulations that accrued to a corporation prior to January 1, 1913, as being capital, not income, for the purposes of the act. And we perceive no adequate ground for a distinction, in this regard, between an accumulation of surplus earnings, and the increment due to an appreciation in value of the assets of the taxpayer. That the dividends in question were paid out of a surplus that accrued to the Central Pacific prior to January 1, 1913, is undisputed; and we deem it to be equally clear that this surplus accrued to the Southern Pacific (Jo. prior to that date, in every substantial sense pertinent to the present inquiry, and hence underwent nothing more than a change of form when the dividends were declared. We do not rest this upon the view that for the purposes of the act of 1913 stockholders in the ordinary case have the same interest in the accumulated earnings of the company before as after the declaration of dividends. The act is quite different in this respect from the income tax act of June 30, 1864 (Ch. 173, 13 Stat., 223, 281, 282), under which this court held in Collector v. Hubbard (12 Wall, 1, 16), that an indi- vidual was taxable upon his proportion of the earnings of the corporation although not declared as dividends. That decision was based upon the very special language of a clause of section 117 of the act (13 Stat., 282) that "the gains and profits of all companies, whether incorporated or partnersliip, other than the companies specified in this section, shall be included in estimating the annual gains, profits, or income of any person entitled to the same, whether divided or otherwise." The act of 1913 contains no similar language, but on the contrary deals with dividends as a par- ticular item of incom.e, leaving them free from the normal tax imposed upon individuals, subjecting them to the grad- uated surtaxes only when received as dividends (38 Stat., 167, par. B), and subjecting the interest of an individual shareholder in the undivided gains and profits of his corpora- tion to these taxes only in case the company is formed or fraudulently availed of for the purpose of preventing the im- position of such tax by permitting gains and profits to ac- 1295 cumulate instead of being divided or distributed.* Our view of the effect of this act upon dividends received by the ordinary stockholder after it took effect but paid out of a surplus that accrued to the corporation before that event, is set forth in Lynch, collector, v. Hornby, decided this day. We base our conclusion in the present case upon the view that it was the purpose and intent of Congress, while taxing "the entire net income arising or accruing from all sources" during each year commencing with the first day of March, 1913, to refrain from taxing that which in mere form only bore the appearance of income accruing after that date, while in truth and in substance it accrued before; and upon the fact that the Central Pacific and the Southern Pacific were in substance identical because of the complete ownership and control which the latter possessed over the former, as stock- holder and in other capacities. While the two companies were separate legal entities, yet in fact, and for all practical purposes they were merged, the former being but a part of the latter, acting merely as its agent and subject in all things to its proper direction and control. And, besides, the funds represented by the dividends were in the actual possession and control of the Southern Pacific as well before as after the declaration of the dividends. The fact that the books were kept in accordance with the provisions of the lease, so that these funds appeared upon the accounts as an indebted- ness of the lessee to the lessor, cannot be controlling, in view of the practical identity between lessor and lessee. Aside from the interests of creditors and the public — and there is nothing to suggest that the interests of either were concerned in the disposition of the surplus of the Central Pacific — the Southern Pacific was entitled to dispose of the matter as it saw fit. There is no question of there being a surplus to warrant the dividends at the time they were made, hence any speculation as to what might have happened in case of financial reverses that did not occur is beside the mark. It is true that in ordinary cases the mere accumulation of an adequate surplus does not entitle a stockholder to divi- dends until the directors in their discretion declare them. New York, etc., Railroad v. Nickals (119 U. S., 296, 306); Gibbons v. Mahan (136 U. S., 549, 558). And see Humphreys V. McKissock (140 U. S., 304, 312). But this is not the ordinary case. In fact the discretion of the directors was affirmatively exercised by declaring dividends out of the surplus that was accumulated prior to January 1, 1913; it does not appear that any other fair exercise of discretion was open; and the complete ownership and right of control ♦'•For the purpose of this additional tax the taxable income of any individual shall embrace the share to which he would be entitled of the gains and profits, if divided or distributed, whether divided or distributed or not, of all corporations, joint- stock companies, or associations however created or organized, formed or fraudulently availed of for the purpose of preventing the Imposition of such tax through the medium of permitting such gains and profits to accumulate instead of being divided or distributed: and the fact that any such corporation • ♦ • is a mere holding company, or that the gains and profits are per- mitted to accumulate beyond the reasonable needs of the business shall be prima facie evidence of a fraudulent purpose to escape such tax; but the fact that the gains and profits are in any case permitted to accumulate and become surplus shall not be con- strued as evidence of a purpose to escape the said tax in such case unless the Secretary of the Treasury shall certify that in his opinion such accumulation Is unreasonable for the purposes of the business." (38 Stat., 166, 167.) 1296 of the Southern Pacific at all times material makes it a matter of indifference whether the vote was at one time or another. Under the circumstances, the entire matter of the declaration and payment of the dividends was a paper trans- action to bring the books into accord with the acknowledged rights of the Southern Pacific; and so far as the dividends represented the surplus of the Central Pacific that accumu- lated prior to January 1, 1913, they were not taxable as in- come of the Southern Pacific within the true intent and meaning of the act of 1913. The case turns upon its very peculiar facts, and is dis- tinguishable from others in which the question of the identity of a controlling stockholder with his corporation has been raised. Pullman Car Co. v. Missouri Pacific Co. (115 U. S., 687, 596); Peterson v. Chicago, Rock Island & Pacific Railway 1205 U. S., 364, 391). Judgment reversed, and the cause remanded for further fjroceedings in conformity with this opinion. Mr. Justice Clarke dissents. (T. D. 2731.) Income Tax Act of October 3, 1913 — Decision of the Supreme Court — 1. Taxing Power Under Sixteenth Amendment. Under the sixteenth amendment to the Constitution, Congress has power to tax as income, without apportion- ment, everything that became income in the ordinary sense of the word after the adoption of the amendment. 2. Retroactive Report. The retroactivity of the act to March 1, 1913 — a date not prior to the adoption of the amendment — is permissible. Brushaber v. Union Pacific Railroad (240 U. S., 1) approved. 3. Taxable Income. An individual stockholder is subject to the additional tax under the 1913 act on all dividends declared and paid by a corporation in the ordinary course of busmess after the taking eftect of the act, whether from current earnings or from the accumulated surplus made up of past earnings or increase in value of corporate assets, notwithstanding the surplus accrued to the corporation in whole or in part prior to March 1, 1913. 4. Cases Distinguished. Lynch, collector, v. Turrish, decided by the Supreme Court June 3, 1918, and Southern Pacific Railway Co. v. Lowe, collector, decided by the Supreme Court June 3, 1915, rest upon their special facts, and are plainly distinguishable. 5. The Act of September 8, 1916, and the Act of October 3, 1917, Discussed. The act of September 8, 1916, and the act of October 3, 1917, in excluding dividends declared out of earnings or profits that accrued prior to March 1, 1913, are not intended to be declaratory of the meaning of the term "dividends'* in the 1913 act. 1297 6. Judgment Reversed. The judgment of the Circuit Court of Appeals is reversed, and the cause remanded to the District Court for further proceedings. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court in the case of E. J. Lynch, as collector of internal revenue, V. H. C. Hornby is published for the information of internal- revenue officers and others concerned. DANIEL C. ROPER, Commissioner ot Internal Revenue. Approved June 11, 1918: L. S. ROWE, Acting Secretary of the Treasury. SUPREME COURT OF THE UNITED STATES. NO. 422. OCTOBER TERM, 1917. E. J. Lynch, Collector of Internal Revenue for the District of Minnesota, petitioner, v. H. C. Hornby. On Writ of Certiorari to the United States Circuit Court of Appeals for the Eighth Circuit. [June 3, 1918.] Mr. Justice Pitney delivered the opinion of the court: Hornby, the respondent, recovered a judgment in the United States District Court against Lynch, as collector, ot internal revenue, for the the return of $171, assessed as an additional income tax under the act of October 3, 1913 (Ch. 16, 38 Stat., 114, 166), and paid under protest. The Circuit Court of Appeals affirmed the judgment (236 Fed., 661), and the case comes here on certiorari. It was submitted at the same time with Lynch, collector, v. Turrish, Southern Pacific Co. v. Lowe, collector, and Peabody v. Eisner, collector, arising under the same act, and this day decided. The facts, in brief, are as follows: Hornby, from 1906 to 1915, was the owner of 434 (out of 10,000) shares of the capital stock of the Cloquet Lumber Co., an Iowa corporation, which for more than a quarter of a century had been engaged in purchasing timber lands, manufacturing the timber into lumber and selling it. Its shares had a par value of $100 each, making the entire capital stock $1,000,000. On and prior to March 1, 1913, by the increase of the value of its timber lands and through its business operations, the total property of the company had come to be worth $4,000,000, and Hornby's stock, the par value of which was $43,400, had become worth at least $150,000. In the year 1914 the company was engaged in cutting its standing timber, manufacturing it into lumber, selling the lumber, and distributing the proceeds among its stockholders. In that year it thus distributed dividends ag- gregating $650,000, of which $240,000, or 24 per cent of the par value of the capital stock, was derived from current earn- ings, and $410,000 from conversion into money of property that it owned or in which it had an interest on March 1, 1913. Hornby's share of the latter amount was $17,794, and this not 1398 having been included in his income tax return, the Commis- sioner of Internal Revenue levied an additional tax of $171 on account of it, and this forms the subject of the present suit. The case was tried in the district court and argued in the Circuit Court of Appeals together with Lynch, collector, v. Turrish (236 Fed., 653), and was treated as presenting sub- stantially the same question upon the merits. In our opinion it is distinguishable from the Turrish case, where the dis- tribution in question was a single and final dividend received by Turrish from the Payette Co. in liquidation of the entire assets and business of the company and a return to him of the value of his stock upon the surrender of his entire interest in the company, at a price that represented its intrinsic value at and before March 1, 1913, when the income tax act took effect. In the present case there was no winding up or liquidation of the Cloquet Lumber Co. nor any surrender of Hornby's stock. He was but one of many stockholders, and had but the ordinary stockholder's interest in the capital and surplus of the company — that is, a right to have them devoted to the proper business of the corporation and to receive from the current earnings or accumulated surplus such dividends as the directors in their discretion might declare. Gibbons v, Mahon (136 U. S., 549, 557). The operations of this company in the year 1914 were, according to the facts pleaded, of a nature essentially like those in whtch it had been engaged for more than a quarter of a century. The fact that they resulted in converting into money, and thus setting free for distribution as dividends, a part of its surplus assets accumu- lated prior to March 1, 1913, does not render Hornby's share of those dividends any the less a part of his income within the true intent and meaning of the act, the pertment lan- guage of which is as follows (38 Stat., 166, 167) : A. Subdivision 1. That there shall be levied, assessed, col- lected, and paid annually upon the entire net income arising or accruing from all sources in the preceding calendar year to every citizen of the United States, ♦ * • and to every person re- siding in the United States, ♦ * * a tax of 1 per centum per annum upon such income, except as hereinafter provided; • ♦ ♦ B, That, subject only to such exemptions and deductions as are hereinafter allowed, the net income of a taxable person shall include gains, profits, and income derived from salaries, wages, or compensation for personal service, • ♦ ♦ also from interest, rent, dividends, securities, or the transaction of any lawful busi- ness carried on for gain or profit, or gains or profits and income derived from any source whatever. Among the deductions allowed for the purpose of the normal tax is "seventh, the amount received as dividends upon the stock or from the net earnings of any corporation, * * • which is taxable upon its net income as hereinafter provided." There is a graduated additional tax, commonly known as a "surtax," upon net income in excess of $20,000, including income from dividends, and for the purpose of this additional tax "the taxable income of any individual shall embrace the share to which he would be entitled of the gains and profits, if divided or distributed, whether divided or distributed or not, of all corporations * * * formed or fraudulently availed of for the purpose of preventing the imposition of such tax through the medium of permitting such gains and profits to accumulate instead of being divided or distributed." It is evident that Congress intended to draw and did draw a distinction between a stockholder's undivided share or in- 1399 tere«t in the gains and profits of a corporation prior to the declaration of a dividend, and his participation in the divi- dends declared and paid, treating the latter in ordinary cir- cumstances as a part of his income for the purposes of the surtax, and not regarding the former as taxable income un- less fraudulently accumulated for the purpose of evading the tax. This treatment of undivided profits applies only to profits permitted to accumulate after the taking effect of the act, since only with respect to these is a fraudulent purpose of evading the tax predicable. Corporate profits that accumu- lated before the act took effect stand on a different footing. As to these, however, just as we deem the legislative intent manifest to tax the stockholder with respect to such accumu- lations only if and when and to the extent that his interest in them comes to fruition as income — that is, in dividends declared— so we can perceive no constitutional obstacle that stands in the way of carrying out this intent when dividends are declared out of a pre-existing surplus. The act took effect on March 1, 1913, a few days after the requisite number of States had given approval to the sixteenth amendment, under which for the first time Congress was empowered to tax income from property without apportioning the tax among the States according to population. Southern Pacific Co. V. Lowe, supra. That the retroactivity of the act from the date of its passage (Oct. 3, 1913) to a date not prior to the adoption of the amendment was permissible is settled by Brushaber v. Union Pacific Railroad (240 U. S., 1, 20). And we deem it equally clear that Congress was at liberty under the amendment to tax as income, without apportion- ment, everything that became income in the ordinary sense of the word after the adoption of the amendment, including dividends received in the ordinary course by a stockholder from a corporation, even though they were extraordinary in amount and might appear upon analysis to be a mere realiza- tion in possession of an inchoate and contingent interest that the stockholder had in a surplus of corporate assets pre- viously existing. Dividends are the appropriate fruit of stock ownership, are commonly reckoned as income, and are ex- pended as such by the stockholder without regard to whether they are declared from the most recent earnings or from a surplus accumulated from the earnings of the past or are based upon the increased value of the property of the corpora- tion. The stockholder is in the ordinary case a different entity from the corporation, and Congress was at liberty to treat the dividends as coming to him ab extra and as con- stituting a part of his income when they came to hand. Hence we construe the provision of the act that "the net income of a taxable person shall include gains, profits, and income derived from * * * interest, rent, dividends, ♦ • • or gains or profits and income derived from any source whatever" as including (for the purposes of the additional tax) all dividends declared and paid in the ordinary course of business by a corporation to its stockholders after the taking effect of the act (Mar. 1, 1913), whether from current earnings or from the accumulated surplus made up of past earnings or increase in value of corporate assets, notwith- standing it accrued to the corporation in whole or in part prior to March 1, 1913. In short, the word "dividends" was employed in the act as descriptive of one kind of gain to the individual stockholder, dividends being treated as the tangible 1300 and recurrent returns upon his stock, analogous to the in- terest and rent received upon other forms of invested capital. In the more recent income-tax acts, provisions have been inserted for the purpose of excluding from the efi'ect of the tax any dividends declared out of earnings or profits that accrued prior to March 1, 1913. This originated with the act of September 8, 1916, and has been continued in the act of October 3, 1917.* We are referred to the legislative history of the act of 1916, which it is contended indicates that the new definition of the term "dividends" was intended to be declaratory of the meaning of the term as used in the 1913 act. We cannot accept this suggestion, deeming it more reasonable to regard the change as a concession to the equity of stockholders granted in the 1916 act, in view of consti- tutional questions that had been raised in this case, in the companion case of Lynch, collector, v. Turrish, and perhaps in other cases. These two cases were commenced in October, 1915, and decisions adverse to the tax were rendered in the District Court in January, 1916, and in the Circuit Court of Appeals September 4, 1916. We repeat that under the 1913 act dividends declared and paid in the ordinary course by a corporation to its stock- holders after March 1, 1913, whether from current earnings or from a surplus accumulated prior to that date, were taxable as income to the stockholder. We do not overlook the fact that every dividend distribu- tion diminishes by just so much the assets of the corporation, and in a theoretical sense reduces the intrinsic value of the stock. But, at the same time, it demonstrates the capacity of the corporation to pay dividends, holds out a promise of further dividends in the future, and quite probably increases the market value of the shares. In our opinion. Congress laid hold of dividends paid in the ordinary course as de facto in- come of the stockholder, without regard to the ultimate effect upon the corporation resulting from their payment. Of course, we are dealing here with the ordinary stockholder ♦In act of September 8, 1916 (Ch. 463, 39 Stat., 756, 757), which took the place of the act of 1913, the substance of what we have quoted from paragraph B of the 3913 act was embodied in sec. 2 (a), but with this proviso: "Provided, that the term 'dividends' as used in this title shall be held to mean any distribution made or ordered to be made by a corporation * ♦ ♦ out of its earnings or profits accrued since March first, nineteen hundred and thirteen, and payable to its shareholders, whether in cash or in stock of the corporation," etc. And by the act of October 3, 1917 (Ch. 63, 40 Stat., 300, 329, 337-8), sec. 2 (a) of the 1916 act was amended by being repeated without the proviso (p. 329), while the proviso was inserted as a new section — 31 (a) — and to It Avas added a subsection (b), as follows: "(b) Any distribution made to the shareholders or members of a corporation ♦ * * in the year nineteen hundred and seventeen, or subsequent tax years shall be deemed to have been made from the most recently accumulated undivided profits or surplus, and shall constitute a part of the annual income of the distributee for the year in which received, and shall be taxed to the distributee at the rates prescribed by law for the years in which such profits or surplus were accumulated by the cor- poration, ♦ ♦ * but nothing herein shall be construed as tax- ing any earnings or profits accrued prior to March first, nineteen hundred and thirteen, but such earnings or profits may be dis- tributed in stock dividends or otherwise, exempt from the tax, after the distribution of earnings and profits accrued since March first, nineteen hundred and thirteen, has been made. This sub- division shall not apply to any distribution made prior to August Bixth, nineteen hundred and seventeen, out of earnings or profits accrued prior to March first, nineteen hundred and thirteen." 1301 receiving dividends declared in the ordinary way of business. Lynch, collector, v. Turrish, and Southern Pacific Co. v. Lowe, collector, this day decided, rest upon their special facts and are plainly distinguishable. It results from what we have said that it was erroneous to award a return of the tax collected from the respondent, and that the judgment should be Reversed, and the cause remanded to the District Court for further proceedings in conformity with this opinion. (T. D. 2732.) Income Tax Act of October 3, 1913 — Decision of the Supreme Court — 1. Taxable Income. A dividend declared and paid by a going corporation partly in cash and partly in assets of the corporation, is subject to the additional tax imposed by the act of Octobei 3, 1913, when received by an individual stockholder, al- though declared from a surplus which was in part accumu- - lated before March 1, 1913. — Southern Pacific Co. v. Lowe collector, decided by the Supreme Court the same day. distinguished. 2. Rights of Stockholders Before Dividends Declared. An ordinary stockliolder, before the declaration of a divi dend, has only the right to have the assets of the cor- poration devoted to its proper business, and to receive such dividends as the directors may in their discretion declare— a very different interest from his interest after a divi- dend is declared. — Lynch, collector, v. Hornby, decided bj the Supreme Court the same day, is controlling. 3. Meaning of "Stock Dividend." A dividend declared and paid by one corporation in the stock of another is not a "stock dividend" within the ac- cepted meaning of that term. 4. Judgment Affirmed. The judgment of the District Court is affirmed. Treasury Department, Office of Commissioner of Internal Revenue Washington, D. C. The appended decision of the United States Supreme Court in the case of Charles A. Peabody v. Mark Eisner, as col- lector of internal revenue, is published for the information ot internal -revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved June 11, 1918 : L. S. ROWE, Acting Secretary of the Treasury. 1302 SUPREME COURT OF THE UNITED STATES. NO. 705. OCTOBER TERM, 1917. Charles A. Peabody, plaintiff in error, v. Mark Eisner, collector of Internal Revenue. In Error to the District Court of the United States for the Southern District of New York. [June 3, 1918.] Mr. Justice Pitney delivered the opinion of the court: This case arose under the Federal income-tax act of October 3, 1913 (Ch. 16, 38 Stat., 114, 166). The controversy is over the first cause of action set up by plaintiff in error in a suit against the collector for the recovery of an additional tax exacted in respect of a certain dividend received by plaintiff in the year 1914, the facts being as follows: On and prior to March 1, 1913, and thenceforward until payment of the dividend in question, petitioner was owner of 1,100 shares (out of a total of 2,000,000 shares outstanding) of common stock of the Union Pacific Railroad Co., of the par value of $100 each, and during the same period the company had large holdings of the common and preferred stocks of the Baltimore & Ohio Railroad Co. On March 2, 1914, the Union Pacific declared and paid an extra dividend upon each share of its common stock, amounting to $3 in cash, $12 in par value of preferred stock of the Baltimore & Ohio, and $22.50 in par value of the common stock of the same company; the result being that petitioner received as his dividend upon his holding of Union Pacific common stock $3,300 in cash, 132 shares of Baltimore & Ohio preferred and 2471/2 shares of Baltimore & Ohio common stock. In his income return for 1914 he included as taxable mcome $4.12 per share of this dividend, or $4,532 in all, and paid his tax upon the basis of this return. Afterwards he was subjected to an additional assessment upon a valuation of the balance of his dividend, and this, having been paid under protest, is the subject of the present suit, the theory of which is that the entire earn- ings, income, gains, and profits from all sources realized by the Union Pacific Railroad Co. from March 1, 1913, to March 2, 1914, remaining after the payment of prior charges, did not exceed $4.12 per share of the Union Pacific common stock, and that the cash and Baltimore & Ohio stock disposed of in the extra dividend (so far as they exceeded the value of $4.12 per share of Union Pacific) did not constitute a gain, profit, or income of the Union Pacific, and therefore did not con- stitute a gain, profit, or income of the plaintiff arising or accruing either in or for the year 1914 or for any period subsequent to March 1, 1913, the date when the income-tax law took effect. The District Court overruled this contention upon the authority of Southern Pacific Co. v. Lowe, collector (238 Fed., 847), and Towne v. Eisner, collector (242 Fed., 702). The latter case has since been reversed (245 U. S., 418), but only upon the ground that it related to a stock dividend which in fact took nothing from the property of the corporation and added nothing to the interest of the share- holder, but merely changed the evidence which represented that interest. Southern Pacific Co. v. Lowe, collector, has been reversed this day, but only upon the ground that the Central Pacific Railway Co., which paid the dividend, and the Southern Pacific Co., which received it, were in substance identical corporations because of the complete ownership and 1303 control which the latter possessed over the former as stock- holder and in other capacities, so that while the two com- panies were separate legal entities, yet in fact and for all practical purposes the former was but a part of the latter, acting merely as its agent and subject in all things to its direction and control; and for the further reason that the funds represented by the dividend were in the actual posses- sion and control of the Southern Pacific Co. as well before as after the declaration of the dividend. In this case the plaintiif in error stands in the position of the ordinary stock- holder, whose interest in the accumulated earnings and sur- plus of the company are not the same before aa after the declaration of a dividend; his right being merely to have the assets devoted to the proper business of the corporation and to receive from the current earnings or accumulated surplus such dividends as the directors in their discretion may declare; and without right or power on his part to control that dis- cretion. It hardly is necessary to say that this case is not ruled by our decision in Towne v. Eisner, since the dividend of Balti- more & Ohio shares was not a stock dividend but a distribu- tion in specie of a portion of the assets of the Union Pacific, and is to be governed for all present purposes by the same rule applicable to the distribution of a like value in money. It is controlled by Lynch, collector, t. Hornby, this day decided. Judgment afiirmed. (T. D. 2733.) Form for Instruments Required Under T. D. 2706 — Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and others concerned: The following form is prescribed to facilitate compliance with T. D. 2706 regarding the establishment of a replacement fund in the case of property requisitioned for war uses or lost or destroyed in whole or in part through war hazards: Form 1114. U. S. Internal Revenue. INCOME AND EXCESS PROFITS TAXES. Application Under T. D. 2706 for Permission to Establish * Replacement Fund. TO THE COMMISSIONER OF INTERNAL REVENUE: 1. The undersigned (individual) (partnership) (corporation) represents that as a result of suit or otherwise he has secured pay- ment by way of damages or compensation for property title to which has been requisitioned for war uses, or property which has been lost or destroyed in whole or in part through war hazards, to an amount in excess of the value of the property on March 1, 1913, or of its cost if acquired after that date, and that he desires and intends to use the entire sum receivd as com- pensation for the replacement in kind of the lost or damaiged property. 2. It being Impracticable owing to war conditions to make Buch a replacement for a considerable time, the undersigned hereby makes application for permission to establish a replace- ment fund In which the entire amount of the compensation so received will be held (unless the property requisitioned, lost or damaged, constituted all or part of the security under a mortgage 1304 or trust Indenture, in which event the amount carried to the replacement fund will, subject to the approval of the Commis- sioner of Internal Itevenue, be the amount of compensation rceived, less the amount, if any, which bcomes payable out of such compensation under the terms of such instrument or the obligations thereby secured). 3. Attached hereto as Schedule A and made a part hereof is a statement reciting all the facts relating to the transaction, includ- ing the nature of the property, the character and extent of the loss, the manner and date of securing compensation, the date of acauisition of the property and its cost or fair value on March 1, 1913, the amount of compensation, the amount necessary to make the damage igood, a description of the replacement intended and the steps already taken to that end, the probable date of com- pletion, the estimated additional excess profits and income taxes assessable upon the income carried to the replacement fund, and ftll other matters which might affect a determination. 4. The undersigned (a) has executed and will cause to be executed by a surety company in good standing the bond hereto annexed as Schedule B in an amount not less than the estimated additional excess profits and income taxes assessable by the United States upon the income carried to the replacement fund, or (b) has executed the agreement hereto annexed as Schedule C and will deposit as security for such estimated additional amount of tax obligations of the United States issued after September 1, 1917, to at least an equal amount, to be held in trust as such security in a bank or trust company approved by the Commis- sioner of Internal Revenue. 5. The undersigned undertakes that he will proceed as expedi- tiously as possible to replace or restore such property, and covenants that when the replacement or restoration is made, the new or restored property will be valued in his accounts at an amount in excess of that at which the requisitioned, damaged or destroyed property was carried, except and to the extent that such new or restored property has an increased productive capacity. IN WITNESS WHEREOF the undersigned Individual has here- unto set his hand and seal, or the undersigned partnership has executed this instrument under the hand and seal of one of its members, or the undersigned corporation has caused these presents to be subscribed by one of its officers and its corporate seal to be hereunto affixed, all the day of , 19 , in triplicate. .._. (L. S.) (L. S.) State of ) County of ] s^. , beimg duly sworn, deposes and says that he is the individual applicant above-named, or is a member of the partnership above-named, or is an officer of the corporation above-named, and that the statements made in the foregoing application are true to the best of deponent's knowledge, information and belief. Subscribed and sworn before me vorn to \ SCHEDULE A. STATEMENT OF FACTS. Name of applicant Address Business Nature of property involved How requisitioned, lost or destroyed How compensation secured Date of rceipt of payment Date of acquisition of property Cost (or fair value on March 1, 1913) $_. Amount of compensation $_. Excess ovijr cost or value on March 1, 1913 |_ 1305 Amount necessary to make damage good f- Nature of replacement intended Steps already taken — Probable date of completion of replacement Amount deductible from replacement fund pursuant to any mortgage | Estimated additional excess profits tax $ Estimated additional income tax $ Surety on bond or bank for deposit of securities SCHEDULE B. BONDS. KNOW ALL MEN BY THESE PRESENTS that , as principal, and , as surety, are held and firmly bound unto the United States of America in the sum of dollars, lawful money of the United States, for the payment whereof we bind ourselves, our heirs, executors, administrators, successors and assigns, jointly and severally, firmly by these presents. WHEREAS the above-bounden principal has made application to the Commissioner of Internal Revenue for permission to estab- lish a replacement fund pursuant to Treasury Decision 2706 of April 25, 1918, and it appears that the amount of this bond is not less than the estimated additional excess profits and Income taxes assessable by the United States upon the income to be carried to the replacement fund ; NOW, THEREFORE, the condition of the foregoing obligation Is such that if the principal shall either dispose of said replace- ment fund, as specified in said application and complete said replacement on or before the final date set in the permit granted by the Commissioner of Internal Revenue, or account for and pay the additional excess profits and Income taxes assessable upon the income so carried to the replacement fund at the rate of tax In force at the time of the original receipt of such Income, and shall otherwise well and truly perform and observe all the covenants and conditions contained In the instruments annexed hereto and all the provisions of law and the regulations, then this obligation Is to be void, but otherwise to remain in full force and virtue. WITNESS our hands and seals In triplicate this day of , 19 Signed, sealed (L. S.) and delivered (L. S.) in the pres- Principal. . ence of (T^. S.) (L. S.) Surety. BOND APPROVED this day of , 19 Commissioner of fnternal Revenue. SCHEDULE C. DEPOSIT AGREEMENT. AN AGREEMENT between of , party of the first part, and a corporation of the State of , party of the second part. WHEREAS the party of the first part has made application to the Commissioner of Internal Revenue for permission to establish a replacement fund under Treasury Decision 2706 of April 25, 1918, In accordance with the Instrument hereto annexed, and has elected in lieu of a bond to deposit as security for the estimated addi- tional excess profits and income taxes assessable by the United States upon the Income to be carried to the replacement fnnd obligations of the United States Issued after September 1, 1917; 1306 NOW, THEREFORE, In consiaeranon of a valuable considera- tion to each of the parties hereto in hand paid by the other, the receipt whereof is hereby acknowledged, it is covenanted and agreed as follows: 1. The party of the first part has deposited with the party of the second part obligations of the United States issued after September 1, 1917, for a principal amount not less than the esti- mated taxes aforesaid, in bearer form or with transfer power attached, described as follows : No. Name Denomination Total $- $ § Aggregate total, $ —. 2. Such obligations are to be held in trust by the party of the second part as security for the payment of the additional excess profits and income taxes assessable by the United States upon the income carried to said replacement fund at the rate of tax in force at the time of the original receipt of such income; provided the party of the first part shall not dispose of said replacement fund as specified in said application and complete said replace- ment on or before the final date set in the permit hereto annexed granted by the Commissioner of Internal Revenue. 3. If on or before the date set in said permit said replacement shall be completed, as evidenced by an acknowledgment in writing to such effect signed by the Commissioner of Internal Revenue, the party of the second part shall thereupon surrender said obligations to the party of the first part or upon his order, and the receipt therefor of the party of the first part shall constitute full satisfaction and discharge of any liability of the party of the second part hereunder. The Commissioner of Internal Revenue may similarly at any time and fi'om time to time author- ize the surrender of such portion of said obligations as in his judgment the progress of said replacement shall justify. 4. If on the date set in said permit the party of the second part shall not have received such final written acknowledgment from the Commissioner of Internal Revenue, it shall hold and deliver said obligations, or the remainder of them, in all respects subject to the order of the Commissioner of Internal Revenue, and at his direction shall proceed to sell said obligations at public or private sale, with or without notice thereof, and shall apply the proceeds thereof to the payment of said taxes and any other taxes due from the party of the first part, and interest, penalties and expenses of the sale, paying the residue, if any, to the party of the first part. After said date the receipt of the Commissioner of Internal Revenue shall constitute full satisfaction and discharge of any liability of the party of the second part hereunder. 5. The party of the second part accepts the trust hereunder and acknowledges the receipt and deposit of said obligations. Signed, sealed and delivered 19 (L S.) (L in the pres- ence of (L. S.^ :_.. (l: S.) AGREEMENT ' APPROVED this day of - — 19 Commissioner of Internal Revenue. PERMIT TO ESTABI.ISH I1EPI.ACEMENT FUND. Treasury Department, OflJce of Commissioner of Internal Revenue, Washington, D. C, -^ , 19 . UPON the application and schedules hereto annexed the Com- missioner of Internal Revenue hereby grants permission to establish a replacement fund pursuant thereto, and directs that pending the disposition of the amount held therein the accountin.g for gain or loss thereupon may be deferred for the period of time ending , 19 , or such further date as he may 1307 determine to be reasonable and endorse hereupon. This permit, however, is expressly conditioned upon the applicant forthwith furnishing a bond in the prescribed form approved by the Com- missioner of Internal Revenue, or executing an agreement in the prescribed form and depositing subject thereto obligations of the United States Issued after September 1, 1917, in an amount and in a bank or trust company approved by the Commissioner of Internal lievenue. Commissioner of Internal Revenue. Instructions. 1. The applicant should execute the form of application in triplicate and fill out Schedule A. He should also attach to Schedule A a statement of any other special features of the situ- ation which might help the Commissioner In arriving at a decision. 2. The applicant should execute the bond (Schedule B) or the deposit agreement (Schedule C) in triplicate, inserting the amount and indicating the surety or bank proposed. 3. The applicant should then forward all three copies of the form to the Commissioner of Internal Revenue, who will consider the application and if he igrants it will sign the permit and return the form of the applicant. 4. The applicant should then forthwith procure the completion of the bond or deposit agreement in triplicate and submit it for approval by the Commissioner, which must be given before the permit will become effective. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: June 17, 1918. L. S. ROWE, Acting Secretary of the Treasury. Printed copies will be furnished upon request. (T. D. 2734.) Determination of the amount of gain or loss on a sale of stock received as a stock dividend — Revision of paragraphs 28 and 60 of the Income Tax Regulations — Treasury Department, Oflfice of Commissioner of Internal Revenue, ♦ Washington, D. C. To Collectors of Internal Revenue and Others Concerned: By Sections 2(a) and 31(a) of the Income Tax Act of Sep- tember 8, 1916, as amended, taxable income includes stock dividends paid by a corporation in 1916 or subsequent years out of its earnings or profits accrued since March 1, 1913, to the amount of the earnings or profits so distributed, and ex- cludes stock dividends paid in 1916 or subsequent years out of surplus other than earnings or profits accrued since March 1, 1913. In Towne v. Eisner, 245 U. S. 418, stock dividends paid in 1913, 1914 and 1915 out of surplus however created were held not to be taxable income under the' Income Tax Act of October 3, 1913. Section 31(b) of the Act of September 8, 1916, as amended, Article 107 of the Income Tax Regulations, and Treasury De- cisions 2659 of February 28, 1918, and 2678 of March 23, 1918, provide the method of determining out of what earninga or 1308 profits a dividend declared in 1917 or subsequent years is deemed to have been paid. For the purpose of ascertaining under the Income Tax Act the gain or loss derived from the sale of stock or other prop- erty, its cost, or if acquired before March 1, 1913, its fair mar- ket price or value as of March 1, 1913, is evidently the basis to be sought. Such basis once found, the problem is resolved into a matter of subtraction. To avoid unnecessary complica- tion "cost" is used herein to include also, where required, "fair market price or value as of March 1, 1913." For the purpose, then of ascertaining the gain or loss de- rived from the sale of stock of a corporation received as a dividend, or from the sale of the stock in respect of which such dividend was paid, the cost of such stock is to be determined in accordance with the following rules: 1. In the case of stock (a) received as a dividend in 1913, 1914 or 1915 out of surplus however created, or (b) received as a dividend in 1916 or subsequent years out of surplus other than earnings or profits accrued since March 1, 1913, the cost of each share of new stock is the quotient of the cost of the old stock divided by the number of old and new shares added together. 2. In the case of the stock in respect of which any stock dividend was paid as described under 1, the cost of each share of old stock is similarly the quotient of the cost of the old stock divided by the number of old and new shares. 3. In the case of stock received as a dividend in 1916 or sub- sequent years out of surplus earnings or profits accrued since March 1, 1913, the cost of each share is the valuation at which it was returnable as income, as shown by the transfer of surplus to capital account on the books of the corporation, usually its par value. 4. In the case of the stock in respect of which any stock dividend was paid as described under 3, the cost of each share is its original cost, regardless of any stock dividend. Paragraph 28 of Regulations No. 33 (revised) is hereby amended to read as follows: Stock Dividends. — Stock dividends declared from earnings or profits accrued prior to March 1, 1913, or from surplus created by the revaluation of capital assets or by placing a value upon trademarks, goodwill, etc., do not represent a distribution of earnings or profits subject to tax as a divi- dend in the hands of the recipient shareholder. When stock received in payment of such a dividend, or stock in respect of which any such dividend was paid, is sold, the cost of each share of stock, whether old or new, for the purpose of ascer- taining the gain or loss resulting from its sale, is the quotient of the cost of the old stock, if acquired on or after March 1, 1913, or its fair market price or value as of that date if ac- quired prior thereto, divided by the number of old and new shares added together. The profit so ascertained from the sale of such stock is income subject to both normal and ad- ditional tax and shall be accounted for in the shareholder's return rendered for the year in which the sale is made. Paragraph 60 of Regulations No. 33 (revised) is hereby amended to read as follows: Profit From the Sale of Stock.— When stock is sold from lots purchased at different times and at different prices and the identity of the lots can not be determined as to the dates of purchase, the stock sold shall be charged against the earli- 1309 est purchases of such stock. The excess of the amount real- ized on the sale over the cost of the stock, or its fair market price or value as of March 1, 1913, if purchased before that date, will be the profit to be accounted for as income. In the case of stock received as a stock dividend out of surplus other than earnings or profits accrued since March 1, 1913, or of stock in respect of which any such dividend was paid, the cost of each share of such stock shall be ascertained as speci- fied in paragraph 28 hereof. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved, June 17, 1918. L. S. ROWE, Acting Secretary of the Treasury. Printed copies will be furnished upon request. (T. D. 2735.) Real estate located outside of the United States belonging to a decedent resident within the United States should not be included in the gross estate of such decedent for estate tax purposes. Treasury Department, Ofi'ice of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: The following ruling is based upon an opinion of the At- torney General, dated May 14, 1918: The value of real estate, belong to a decedent resident within the United States at the time of his death, located out- side of the United States, meaning thereby the States' Terri- tories of Alaska and Hawaii^i and the District of Columbia, should not be included in determining the value of the gross estate of such decedent for the purpose of the tax imposed by Title II. of the Revenue Act of September 8,, 1916. DANTIEL C. ROPER, Commissioner of Internal Revenue. Approved, June 17, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2736.) Tax on undistributed net income of corporations, joint stock companies and associations, and insurance companies. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: 1. Statute.— Section 10(b) added to Title I of the Revenue Act of September 8, 1916, by Section 1206 of Title XII of the War Revenue Act of October 3, 1917, is as follows: In addition to tlie Income tax imposed by subdivision (a) of this section tiiere siiall be levied, assessed, collected, 1310 and paid annually an additional tax of ten per centum upon the amount, remaining undistributed six months after the end of each calendar or fiscal year, of the total net income of every corporation, joint-stock company or association, or insurance company, received during the year, as determined for the purposes of the tax imposed by such subdivision (a), but not including the amount of any income taxes paid by it within the year imposed by the authority of the United States. The tax imposed by this subdivision shall not apply to that portion of such undistributed net income which is actually invested and employed in the business or is re- tained for employment in the reasonable requirements of the business or is invested in obligations of the United States issued after September first, nineteen hundred and seventeen: Provided, That if the Secretary of the Treas- ury ascertains and finds that any portion of such amount so retained at any time for employment in the business is not so employed or is not reasonably required in the business a tax of fifteen per centum shall be levied, as- sessed, collected, and paid thereon. The foregoing tax rates shall apply to the undistributed net income received by every taxable corporation, joint- stock company or association, or insurance company in the calendar year nineteen hundred and seventeen and in each year thereafter, except that if it has fixed its own fiscal year under the provision of existing law. the fore- going rates shall apply to the proportion of the taxable undistributed net income returned for the fiscal year end- ing prior to December thirty-first, nineteen hundred and •eventeen, which the period between January first, nine- teen hundred and seventeen, and the end of such fiscal year bears to the whole of such fiscal year. 2. Definitions, Corporation. — The term "corporation" or "cor- porations" as used in this Treasury Decision shall be con- strued to include all corporations, joint-stock companies and associations, and insurance companies, coming within the terms of Title I of the Act of September 8, 1916, as amended by Title XII of the Act of October 3, 1917. Taxable Year. — The term "taxable year" as used in this Treasury Decision contemplates the calendar year 1917 and each calendar year thereafter, or in the case of a corporation properly filing its income returns upon the basis of a fiscal year other than the calendar year, the fiscal year ending in 1917 and each fiscal year thereafter. 3. Corporation Subject to Tax. — Every corporation, domestic or foreign, which was subject to taxation upon the total net income received by it during the preceding taxable year is subject to the provisions of Section 10(b) added to the Act of September 8, 1916, by "Section 1206 of the Act of October 3, 1917, which impose a tax upon undistributed net income. Corporations which are exempt under the provisions of Sec- tion 11(a) of the Act of September 8, 1916, from tax upon total net income are not taxable upon undistributed net in- come under said Section 10(b). 4. Returns. — Every corporation which is required by the provisions of the Act of September 8, 1916, as amended by the Act of October 3, 1917, to make a return of its annual net income, and which had a taxable net income for the preceding taxable year, shall make a return of the amount of such net income received during such taxable year re- maining undistributed six months after the end of such tax- able year. The return shall be made upon Form 1112, shall be sworn to by the president, vice-president or other principal officer, and by the treasurer or assistant treasurer of the cor- poration and shall be made to the Collector of Internal Rev- enue of the district in which its return of annual net income is required to be filed. Such return shall be made within sixty 1311 days after the expiration of six months after the end of such taxable year, except that any corporation which would other- wise be required to make a return on or before a date earlier than August 1, 1918, may make such return on or before August 1, 1918. 5. Rate of Tax. — Taxes are imposed by Section 10(b) of the Act of September 8, 1916, as amended, at two different rates, ten per cent and fifteen per cent. 6. Income Subject to the Ten Per Cent Tax. — The amount of income subject to the ten per cent tax is to be ascertained in the following manner: From the total net income received by a corporation during its taxable year as determined for the purposes of the annual tax imposed thereon by subdivision (a) of Section 10 of the Act of September 8, 1916, as amended, which remains undis- tributed six months after the end of such taxable year, are to be deducted (1) the amount of any income taxes imposed by the authority of the United States paid by the corporation within such taxable year from income of that year, (2) such part of the undistributed income as is actually invested and employed in the business, or (3) is retained for employment in the reasonable requirements of the business, or (4) is in- vested in obligations of the United States issued after Sep- tember 1, 1917. If the taxable year began on or after Janu- ary 1, 1917, the remainder is the amount upon which the tax is assessed. If the taxable year began before January 1, 1917, the proportion of such remainder which the period between January 1, 1917, and the end of such taxable year bears to the whole of such taxable year is the amount upon which the tax is assessed. Income received by a corporation before the beginning of a taxable year ending in 1917 is not subject to the tax even though remaining undistributed six months after the end of such taxable year. 7. Time of Determining Amount of Undistributed Income Subject to Ten Per Cent Tax. — The amount of undistributed net income subject to ten per cent tax is to be determined as of a date six months after the end of the taxable year. Changes in the amount of such undistributed income after such date do not change the amount subject to ten per cent tax. The Commissioner of Internal Revenue has no authority to change the date as of which the amount of undistributed net income subject to ten per cent tax is determined, either in the case of a taxable year ending before October 3, 1917, or of any other taxable year. 8. Undistributed Income. — The net income received by a cor- poration during its taxable year remains undistributed until it is distributed in the form of dividends, whether it is repre- sented by liquid assets or otherwise. Income distributed in the form of dividends is subject to the provisions of Section 31(b) added to the Act of September 8, 1916, by Section 1211 of the Act of October 3, 1917, which provides in part as follows : Any distribution made to the shareholders or members of a corporation, joint-stock company, or association, or insurance company, in the year nlijetoen hundred and seventeen, or subsequent tax years, shall be deemed to have been made from the most recently accumulated un- divided profits or surplus. • ♦ ♦ The burden is upon the corporation seeking to establish a distribution in the current year of profits of the preceding taxable year to show that all the earnings of the current 1313 year have been first distributed. In determining the source of earnings from which a particular distribution is made a corporation is, however, permitted to treat the undivided profits and surplus of the current year as reduced by pay- ments for income and excess-profits taxes, or if keeping its accounts on an accrual basis by proper reserves for such taxes, although such payments or reserves are not deductible in com- puting the income of the corporation for income and excess- profits taxes. (Treasury Decision 2700. See also Treasury Decision 2659, and Treasury Decision 2678). 9. "The Business" of a Corporation. — "The business" of a corporation is not limited to the business which the corpora- tion has previously carried on but includes any line of busi- ness which the corporation may legitimately undertake. When one corporation owns the stock of another corporation in the same or a related line of business and in effect operates the other corporation, the business of the other corporation falling within the general scope of the powers of the first, that business may be in effect although not in legal form the business of the first corporation. Income of the first corpora- tion may be put into the second through the purchase of stock or otherwise and might, if the subsidiary relationship is established, constitute employment of the income in its own business. For such employment to fall within the ex- ception it would be essential for the corporation to show the same facts with reference to the actual utilization of the funds so employed, or their retention for its reasonable re- quirements which it would be necessary for the corporation to show with reference to funds employed or retained directly by it. Investment by a corporation of income in securities of an- other corporation is not, without more, to be regarded as em- ployment of the income in "the business." The business of one corporation may not be regarded as including the busi- ness of another, within the meaning of that exception, unless the other corporation is a mere instrumentality of the first; to establish this it is ordinarily essential that the first cor- poration own all of the stock of the second. 10. Undistributed Income "Actually Invested and Employed in the Business." — The portion of undistributed net income which is "actually invested and employed in the business" is not subject to the ten per cent tax. No attempt is here made to enumerate all the ways in which such undistributed in- come may be so invested and employed. Undistributed income i» used or employed in the business if invested in increased inventories or additions to plant reasonably required by the business; if used for the payment of income and excess- profits taxes for the taxable year, provided the amounts so paid are designated upon the books of the corporation as made from the income of such taxable year; if used to make good an impairment of capital when such income is by law required to be so used; or if used to retire the whole or any part of the capital stock of the corporation, but reserves set up for this purpose are neither invested and employed in the business, nor retained for employment in the reasonable re- quirements of the business. In the case of a banking institu- tion the business of which is to receive and loan money, using capital, surplus and deposits for this purpose, undistributed income actually represented by loans is invested and employed in the business. 1313 11. Undistributed Income "Retained for Employment in the Reasonable Requirements of the Business." — The portion of undistributed net income which is "retained for employment in the reasonable requirements of the business" is not subject to the ten per cent tax. No attempt is here made to enumer- ate all the ways in which such undistributed income may be retained. Undistributed income is retained for employment in the reasonable requirements of the business if to a reasonable amount it is retained to make good an impairment of capital when such income is by law required to be so used; or in ac- cordance with contract requirements placed in the credit of a sinking fund for the purpose of retiring bonds issued by the corporation; or retained for working capital required by the business. In the case of a banking institution the business of %\hich is to receive and loan money, using capital, surplus and deposits for this purpose, such reasonable amounts of un- distributed net income as are retained for future loans are not subject to the ten per cent tax. 12. Undistributed Income "Invested in Obligations of the United States Issued After September First, Nineteen Hundred and Seventeen." — ^Undistributed net income "invested in obli- gations of the United States issued after September first, nineteen hundred and seventeen" is not subject to the ten per cent tax. This is not true of obligations of the United States issued before September 1, 1917. The restrictions as to the distribution of earnings of previ- ous taxable years resulting from the presumption that all current distributions are from current earnings do not apply to the use of earnings for investments by corporations. There is in the statutes no limitation or restriction as to the source from which may be taken earnings used for this purpose. Amounts invested in obligations of the United States issued after September 1, 1917, may thus be treated as made from such earnings as the corporation may designate. (Treasury Decision 2700). 13. Income Subject to Fifteen Per Cent Tax.— If the Secre- tary of the Treasury ascertains and finds that any portion of the undistributed net income retained at any time for em- ployment in the business is not so employed, or is not reason- ably required in the business, it is subject to a tax of fifteen per cent. The liability of undistributed net income to the ten per cent tax depends upon the manner in which it is invested on the date six months after the end of the taxable year. However, the status of the income is not lost by the invest- ment, but persists for the possible application of the fifteen per cent tax. Amounts of undistributed net income not sub- ject to the ten per cent tax because of employment in the business, retention for such employment or investment in cer- tain obligations of the United States, become subject to the fifteen per cent tax if retained after such investment, employ- ment or retention for employment in the reasonable require- ments of the business has ceased. 14. Penalty for Nonpayment.— If the tax assessed on un- distributed net income is not paid within ten days after the date of notice and demand therefor it* shall be the duty of the collector to collect said tax with a penalty of five per cent additional upon the amount thereof and interest at the rate of one per cent a month. 15. Other Penalties. — In case of any failure to make and file a return within the time prescribed by law fifty per cent 1314 of the amount of the tax shall be added thereto, except that when a return is voluntarily and without notice from the col- lector filed after such time, and it is shown that the failure to file it was due to reasonable cause and not to wilful neglect no such addition shall be made to the tax. In case a false or fraudulent return is wilfully made one hundred per cent of the amount of the tax shall be added thereto. Corporations, officers thereof and other individuals required to make, render, sign or verify returns of corporations shall be subject to the specific penalties provided by law for refusal or neglect to make such returns and for making false or fraudulent returns. 16. Extension of Regulations No. 33 (Revised). — ^Regulations No. 33 (Revised), dated January 2, 1918, and all subsequent Treasury Decisions so far as they are applicable to the taxes imposed by subdivision (b) added to Section 10 of the Act of September 8, 1916, by 'Section 1206 of the Act of October 3, 1917, are hereby extended and made a part of this Treasury Decision in so far as they do not conflict with the rulings contained herein. Article 238 of said Regulations No. 33 (Re- vised) is hereby revoked. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved, June 18, 1918. L. S. ROWE, Acting Secretary of the Treasury. Printed copies will be furnished upon request. (T. D. 2737.) Co-operative merchandising organizations are subject to the provisions of the Act of September 8, 1916, as amended by the Act of October 3, 1917. Periodical refunds made to purchasers are to be regarded as discounts, reducing the organization's net income. The recipient need not return them as income, but should treat sums so received as rebates, reducing the cost to him of the purchases on which the refund is based. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: Co-operative societies, associations or corporations which make a periodical refund — sometimes called a dividend — to members or to prospective members or to patrons generally, in proportion to the purchases made by the recipient, are not within any of the exceptions or exemptions of the Act of September 8, 1916, as amended by the Act of October 3, 1917, and are subject to its provisions. Where such refund payments are made in accordance with by-laws or published rules regularly adhered to, they are to be regarded as discounts or rebates tending to reduce the taxable net income of the organization. Like discounts gen- erally, they should appear as an added item of cost in the detailed schedule of cost items submitted with the organiza- tion's return of income. This ruling is in accordance with settled practice in the 1315 administration of the income tax laws, adopted because the real purpose of such organizations is to fuiuish goods at cost. So-called "dividends" of this character are wholly different from ordinary dividends based on stock-holdings, and they need not be listed as income by the recipient. However, if the recipient is claiming the right to deduct as business ex- penses any expenditure on which the refund is based in whole or in part, the sum claimed as a deduction must be reduced in proportion to the refund received. DxlNIEL C. ROPER, Commissioner of Internal Revenue. Approved June 19, 1918: L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2740.) Corporation Excise Tax and Income Taxes. Digest of Recent Decision of the Supreme Court of the United States. Treasury Department, OflB.ce of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: The following propositions of law, stated for the informa- tion and guidance of internal revenue officers and others con- cerned, are expressed or implied in the recent decisions of the Supreme Court of the United States in United States v. Biwabik Mining Company (T. D. 2721), Goldfield Consolidated Mines Company v. Scott (T. D. 2722), Doyle v. Mitchell Bros. Co. (T. D. 2723), Hays v. Gauley Mountain Coal Company (T. D. 2724), United States v. Cleveland, Cincinnati, Chicago & St. Louis Railway Company (T. D. 2725), William E. Peck & Co. (Inc.) V. Lowe (T. D. 2726), Lynch v. Turrish (T. D. 2729), Southern Pacific Company v. Lowe (T. D. 2730), Lynch V. Hornby (T. D. 2731), and Peabody v. Eisner (T. D. 2732): 1. In the determination of net income the Excise Tax Act of August 5, 1909, permitted the deduction from gross income of "a reasonable allowance for depreciation of property, if any;" the Income Tax Act of October 3, 1913, permitted "a reasonable allowance for the exhaustion, wear and tear of property arising out of its use or employment in the busi- ness, not to exceed, in the case of mines, 5 per centum of the gross value at the mine of the output for the year for which the computation is made;" and the Income Tax Act of September 8, 1916, as amended, permits "in the case of mines a reasonable allowance for depletion thereof not to exceed the market value in the mine of the product thereof which has been mined and sold during -the year for which the return and computation are made." (a) As mining leases are not conveyances of the ore in place, but are grants of the privilege of entering upon the premises and mining and removing the ore, under none of the Acts of 1909, 1913 or 1916 may a lessee of mining prop- 1316 erty deduct as so much depletion of capital assets the pro- portionate value in place on January 1, 1909, or any other date, of each ton of ore mined during the taxable year. See T. D. 1606 (75); Article 145 of Regulations No. 33; and Articles 8, 171 and 173 of Regulations No. 33 (revised). (United States v. Biwabik Mining Company. See Von Baum- bach V. Sargent Land Company, 242 U. S. 503.) (b) Under the Act of 1909 a mining corporation owning its mine is not entitled to a deduction from its gross income of any amount whatever on account of depletion or ex- haustion of the ore bodies caused by its operations for the year for which the tax is assessed, nor to a deduction against the gross proceeds frjom the mining and treatment of ores to the extent of the cost value of the ore in the ground before it was mined. T. D. 1675 (80-89) and T. D. 1742 (96-106) are modified accordingly. In view of their different provisions this rule is inapplicable to situations arising under the Acts of 1913 and 1916. See Articles 141 and 142 of Regulations No. 33; and Articles 8, 171 and 172 of Regulations No. 33 (revised). (Goldfield Consolidated Mines Company v. Scott. See Strat- ton's Independence v. Howbert, 231 U. S., 399; Stanton y. Baltic Mining Company, 240 U. S., 103.) 2. The Excise Tax Act of August 5, 1909, measured the tax by the net income of a corporation "received" by it from all sources during the taxable year; the Income Tax Act of October 3, 1913, imposed the tax upon the net income "arising or accruing" from all sources during the taxable year; and the Income Tax Act of September 8, 1916, as amended, upon the net income "received" from all sources during the taxable year. (a) Where property is acquired by a corporation and sub- sequently sold for a higher price, under all three Acts the gain on the sale is income to the corporation. If, however, the property was acquired before January 1, 1909, only such portion of the gain as accrued subsequent to December 31, 1908, was taxable under the Act of 1909, and if it was ac- quired before March 1, 1913, only such portion of the gain as accrued subsequent to February 28, 1913, was taxable under the Act of 1913 or is taxable under the Act of 1916. See Regulations No. 31, T. D. 1606 (40, 50, 76), T. D. 1675 (37, 48, 75), T. D. 1742 ]43, 55, 91); and Articles 88, 101 and 116 of Regulations No. 33 (revised). (Doyle v. Mitchell Bros. Company; Hays v. Gauley Mountain Coal Company; United States V. Cleveland, Cincinnati, Chicago and St. Louis Rail- way Company.) (b) In order to determine whether there has been gain or loss on a sale, and the amount of the gain, if any, in general under all three Acts an amount must be withdrawn from the gross proceeds sufficient to restore the cost of the prop- erty or the capital value that existed at the commencement of the period imder consideration (either January 1, 1909, or March 1, 1913). Interest should not be added to the purchase price in order to ascertain the cost of the property. In ap- portioning the profits derived from a disposition of property acquired before and sold after January 1, 1909, for the pur- pose of the Act of 1909, or acquired before and sold after March 1, 1913, for the purpose of the Act of 1913, the division may be pro rata according to the time elapsed or may be based on an appraisal or inventory taken as of December 31, 1908, or February 28, 1913. This is a matter of detail, to be 1317 settled according to the best evidence obtainable and in ac- cordance with valid departmental regulations. For the pur- pose of the Act of 1916, however, the fair market price or value as of March 1, 1913, to be ascertained in any practic- able manner, is the statutory basis for determining the amount of gain on a sale of property acquired before that date. See Regulations No. 31, T. D. 1578, T. D. 1588, T. D. 1606 (37, 71), T. D. 1675 (36, 55, 69), T. D. 1742 (42, 62, 86); Articles 4, 90, 91, 92, 93, 101, 109, 111, 112 and 116 of Regulations No. 33 (revised), and T. D. 2649. (Doyle v. Mitchell Brothers Company; Hays v. Gauley Mountain Coal Company; United States V. Cleveland, Cincinnati, Chicago and St. Louis Rail- way Company.) (c) The Act of 1913 is valid and constitutional in taxing net income derived from sales in foreign commerce. The same principle applies to the Acts of 1909 and 1916. (William E. Peck and Company (Inc.) v. Lowe.) (d) Where a stockholder in a corporation receives as a liquidation dividend, representing his share in the distribution of the proceeds of the sale of the property of the corporation upon dissolution, a sum greater than the cost of his stock under the Acts of both 1913 and 1916 the gain is income to the stockholder. If, however, he acquired the stock before March 1, 1913, only such portion of the gain as accrued subse- quent to February 28, 1913, was taxable under the Act of 1913 or is taxable under the Act of 1916. Compare the case of a dividend in ordinaiy course in paragraph (f) below. See the citations in paragraphs (a) and (b) above. (Lynch v. Turrish.) (e) Wliere a corporation owns all the stock and operates under a lease all the property and business of another cor- poration, acting as banker for it, and the two corporations being in substance identical and merged for all practical pur- poses, under the Acts of both 1913 and 1916 surplus of the lessor corporation accrues as income to the lessee corporation as and when accumulated by the lessor corporation, notwith- standing the formal distribution of such surplus in dividends to the lessee corporation may not occur during the taxable year. This special situation forms an exception to the gen- eral rule stated in paragraph (f) below. See Articles 125, 207 and 208 of Regulations No. 33 (revised). (Southern Pacific Company v. Lowe.) (f) Where a stockholder of a corporation receives dividends paid in the ordinary course of business, even though extra- ordinary in amount, under the Acts of both 1913 and 1916 such dividends are income in the year in which they are received by the stockholder. If paid out of surplus accrued to the corporation prior to March 1, 1913, they were subject to tax imder the Act of 1913, although expressly exempt from tax under the Act of 1916. A dividend paid by a going corporation out of current earnings or accumulated surplus when declared by the directors in their discretion, being in the nature of a recurrent return upon the stock, is distinguish- able from a so-called dividend in liquidation of the entire assets and business of the corporation, which is a return to the stockholder of the value of his stock upon the surrender of his entire interest in the corporation. Compare the case of a liquidation dividend in paragraph (d) above. See Articles 105, 106 and 107 of Regulations No. 33 (revised), T. D. 2659 and T. D. 2678. (Lynch v. Hornby; Peabody v. Eisner.) 1318 (g) A dividend in ordinary course paid on stock of a cor- poration in property or stock other than its own is income to the stocldiolders to the amount of its cash value when received under the Acts of both 1913 and 1916. A dividend paid in stock of another corporation is not a stock dividend. See Articles 4 and 106 of Regulations No. 33 (revised). (Peabody v. Eisner; compare Towne v. Eisner, 245 U. S., 418.) DANIEL C. ROPER, Commissioner. Approved June 24, 1918: L. S. ROWE, Acting Secretary of the Treasury. (T. D. No. 2744.) Returns made upon the basis of "cost or market value, whichever is lower" to be accepted; T. D. 2609 as supple- mented by T. D. 2649 affirmed. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue, Revenue Agents and Others Concerned : As question had arisen as to the legality of the authorization by Treasury Decision No. 2609 of returns for income and excess profits tax purposes upon the basis of inventories taken "at cost or market value, whichever is lower," the matter was referred to the Attorney-General. (See T. D. 2649.) The Attorney-General has advised upon the basis of a recent deci- sion of the Supreme Court (Doyle v. Mitchell Brothers, decided May 20th last), that the methods of taking inventories au- thorized by Treasury Decision No. 2609 are permissible. That decision supplemented by the last paragraph of Treasury De- cision No. 2649 defining "a dealer in securities" therefore con- tinues to stand as a regulation of the Department. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: July 3, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2747.) Proceeds of Accident Insurance Policies Received by Indi- viduals on Account of Personal Injuries Sustained Through Accident. Treasury Department, Office of Commissioner of Internal Revenue^ Washington, T>. C. To Collectors of Internal Revenue and Others Concerned: The Attorney General has advised upon the basis of recent decisions of the Supreme Court (Doyle v. Mitchell Brother i 1319 Company, decided May 20, last; Lynch v. Hornby, Lynch v. Turrish and Southern Pacific Company v. Lowe, decided June 3, last) and it is accordingly held that the proceeds of an accident insurance policy received by an individual on account of personal injuries sustained by him through accident are not income taxable under the provisions of Title I. of the Act of September 8, 1916, as amended by Title XII. of the Act of October 3, 1917, and of Title L of the Act of October 3, 1917. It is held upon similar principles that an amount received by an individual as the result of a suit or compromise for personal injuries sustained by him through accident is not Income taxable under the provisions of said Titles. Such provisions of Treasury Decisions and of Regulations No. 33 (Revised) as are inconsistent herewith are hereby re- voked. DANIEL C. ROPER, Commissioner. Approved: July 12, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2754) Basis of Allowances for Depreciation — Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and others concerned: Section 12(a) of the Act of September 8, 1916, as amended, to which Section 5(a) is similar, provides that net income shall be ascertained by deducting from gross income, among other things : "Second. All losses actually sustained and charged oflf within the year and not compensated by insur- ance or otherwise, including a reasonable allowance for the exliaustion, wear and tear of property arising out of its use or employment in the business or trade." A reasonable allowance for the wear and tear of property arising out of its use or employment in the business or trade is to be based on the cost of such property or on its fair market price or value as of March 1, 1913, if acquired prior thereto. In the absence of proof to the contrary it will be assumed that such value as of March 1, 1913, is the cost of the property, less depreciation up to that date. This decision is supplemental to Article 159 to 169 inclusive of Regulations No. 33 (revised), which to any necessary extent are modified accordingly. (Signed) D'ANIEL C. ROPER, Commissioner. Approved: August 23, 1918. (Signed) JAMES H. MOYLE, Acting Secretary of the Treasiury. 1320 (T. D. 2755) Depositaries and Sureties Acceptable Under T. D. 2706 and T. D. 2733— Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and others concerned: To facilitate compliance with the provisions of T. D. 2706, which permits the establishment of a replacement fund in the case of property requisitioned for war uses or lost or de- stroyed in whole or in part through war hazards, applicants are notified that only active depositaries of public moneys and surety companies holding certificates of authority from the Secretary of the Treasury as acceptable sureties on Fed- eral bonds will be approved as sureties or depositaries under Schedule B and C of form 1114, prescribed by T. D. 2733. (Signed) DANIEL C. ROPER, Commissioner. Approved: August 26, 1918. (Signed) JAMES H. MOYLE, Acting Secretary of the Treasury. (T. D. 2756.) (1) Conditions under which five per cent discount may be allowed for advance payment of estate tax. (2) Conditions under which a tentative return may be filed. (3) Granting of extension in which to file final return. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: FIVE PER CENT DISCOUNT. Section 204 of the Estate Tax Law (Act of September 8, 1916) provides that estate tax shall be due one year after decedent's death, and if the tax is paid before it is due a discount at the rate of five per centum per annum, calculated from the time payment is made to the date when the tax is due, shall be dediicted. Discount is not allowable unless the total tax be determined and advance payment made in full. It is not contemplated by the Act that immediately after a decedent's death, or at any time before the expiration of the year, the executor may make partial payment on account of the tax and receive credit for the discount because of ad- vance payment. If advance payment is to be made before the due date of the tax, the estate must be in a position to tile a final return on Form 706 showing the value of all assets as of the date of decedent's death and the alloAvable deduc- tions to which the estate is entitled under Section 203 of the Act, the value of the net estate and the determined tax be- cause of the transfer of the net estate. 1321 Final return must be filed wherever advance payment is de- sired and the amount paid should be entered upon the col- lector's assessment list for the month in which paid as advance collection. TENTATIVE RETURN. Section 207 of the Estate Tax Act provides that if for any reason the amount of the tax cannot be determined the pay- ment of a sum of money sufficient in the opinion of the col- lector to discharge the tax shall be deemed payment in full of the tax, etc. This provision clearly relates to the time when the tax is due. The collector is not required to exercise his discretion as to what amount will satisfy the tax until the due date thereof. It is obvious that no discount is allow- able upon such payment, as necessarily the payment cannot be made before the expiration of a year following decedent's death. The following regulations govern the above payments: If at the end of the year following decedent's death the executor represents and the collector is satisfied that the amount of tax upon the estate cannot be determined, a return may be filed by the executor setting forth the then known assets of the estate and the actual value thereof as of date of decedent's death, the determined and allowable deductions to which the estate is entitled, the value of the net estate thus disclosed and the tax due thereon. This return will be designated "tentative." The tax shown to be due upon the tentative return should be paid and entered upon the collec- tor's assessment list for the month in which paid. As further provided in Section 207 of the Act, if the amount of tax as finally determined is less than the amount paid upon the basis of the tentative return the Commissioner will, upon filing claim on Form 46, make refund of the excess pay- ment. If the amount of tax as finally determined exceeds the amount so paid the Commissioner will notify the executor of such excess. From the time of such notification to the time of final payment of such excess part of the tax interest will be added thereto at the rate of ten per centum per annum. EXTENSION FOR FILING FINAL RETURN. At the time the "tentative" return is filed an extension not to exceed ninety days may be granted by the collector in which to file a final return. If at the expiration of the extension granted the executor represents that he is still unable to determine the tax and file final return a detailed statement as to the reason preventing the determination of the tax should be transmitted to the Bureau for considera- tion as to whether an additional extension should be granted. In every case where a tentative return is filed it should be plainly so designated and a duplicate thereof transmitted to the Bureau with a statement by the collector as to the period of extension granted. All regulations and treasury decisions inconsistent with the ruling contained herein are hereby modified. DANIEL C. ROPER, Commissioner. Approved: September 5, 1918. L. S. ROWE, Acting Secretary of the Treasurv. 1323 (T. D. 2759.) Amending Article 35, Regulations No. 33, Revised, and Treas- ury Decision 2716, by providing that the first collecting bank or agent shall be the source of information in all cases of foreign items except where the item is an interest item; that, where a foreign country or corporation issuing the interest -bearing obligations has a paying agent in this country, such paying agent shall be the source of informa- tion; and that, if no such agent has been appointed then the last bank or collecting agent in this country which handles the interest item shall be the source of informa- tion. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. 0. To Collectors of Internal Revenue and Others Concerned: 1. Article 35, regulations No. 33, Revised, as amended by Treasury Decision 2716, is hereby amended to read as follows: Article 35. Such returns of information shall be re- quired, regardless of amount, in the case of payments of interest upon bonds, mortgages, or deeds of trust or other similar obligations of domestic or resident corporations, joint-stock companies, associations, and insurance com- panies, and in the case of foreign items. The original ownership certificates when duly filed, shall constitute and be treated as returns of information. The term "foreign item," as used in this Article, means any dividend upon the stock of a foreign corporation, or any item of interest upon the bonds of foreign countries or foreign corporations, whether or not such dividend or interest is paid in the United States, or by check drawn on a domestic bank. The term "foreign corporation" as uged in this article, means one not organized and existing under the laws of the United States or of any State or Territory thereof, or of the District of Columbia, Porto Rico, or the Philippine Islands. Wherever a foreign country or foreign corporation issu- ing bonds has appointed a paying agent in this country, charged with the duty of paying the interest upon such bonds, such paying agent shall be the source of informa- tion. If such foreign country or foreign corporation has no such agent then the last bank or collecting agent in this country shall be the source of information. In the case of dividends on the stock of a foreign corporation, the first bank or collecting agent accepting such item for collection shall be the source of information. Where bonds of foreign countries, or bonds or stocks of foreign corporations, are owned by citizens or resi- dents of the United States, individual or fiduciary, or by domestic or resident corporations, joint stock companies, associations, Insurance companies or partnerships, owner- ship certificate lOOlA shall be executed by the actual owner, or by his duly authorized agent, when presenting the item for collection, whether such item is a dividend or an interest payment, except in the case of a foreign country or a foreign corporation having a paying agent in this country and issuing bonds which contain a '^tax-free" covenant clause. In such cases the paying agent is re- quired to withhold the normal tax upon the interest on such bonds; and ownership certificate. Form 1000, prop- erly modified to show that the debtor has a paying agent in this country, should be used, unless the owner desires to claim exemption ; in which case Form lOOlA should be filed. Where bonds of foreign countries, or bonds or stocks of foreign corporations, are owned by nonresident alien individuals, or foreign corporations, associations or part- nerships, ownership certificate. Form 1071, Revised, shall 1323 be used for and on behalf of such owners by any respon- sible bank or banker, either foreign or domestic. Banks or agents collecting foreign items are required to obtain a license from the Commissioner of Internal Revenue to engage in such business, and are subject to such regulations for the furnishing of Information as the Commissioner, with the approval of the Secretary of the Treasury, shall prescribe, and to the penalties prescribed for failure to obtain such license (Act of September 8, 1916, Section 9 (f), as amended by Act of October 8, 1017, Section 120G). A blank application (Form 1017) for such license may be obtained, upon request, from any collector of internal revenue. This license is issued without cost. Foreign items shall not be accepted for collection by any bank or collecting agent so licensed unless endorsed as hereinafter provided or accompanied by proper owner- ship certificates (Form 1001-A, Form 1000, properly modi- fied as outlined above, or Form 1071, Revised, as the case may be), giving all information called for by such cer- tificate. In all cases in which the first licensed bank or collecting agent is the source of information, such licensee shall detach the ownership certificate, and indorse on the item the words "Certificate detached and Information furnished," adding his name and address. Where an in- terest coupon is received for collection, the ownership certificate shall accompany the coupon to the paying agent In this country, or, if there is no such agent, then to the last bank or collecting agent handling the item in this country. When more than one coupon of the same ma- turity is received at one time from the same owner and from the same issue of bonds, a single certificate may be used for all of such coupons. When foreign items have been indorsed as above prescribed, the certificates shall be detached and forwarded to the Commissioner of In- ternal Revenue (Sorting Division), Washington, D. C, on or before the 20th day of the month following that during which the items were accepted, accompanied by a letter of transmittal, showing the number of certificates, and the aggregate amount of foreign items disclosed thereon. In all cases in which the paying agent or the last bank or collecting agent in this country is the source of in- formation, the ownership certificate shall accompany the coupon to such agent or source of Information, who shall forward the ownership certificate to the Commissioner of Internal Revenue, in the manner provided where such duty is placed upon the licensee: Provided, however, that, in case ownership certificate. Form 1000, is used as pro- vided above, the paying agent shall make return on Form 1012 as provided in the Regulations. 2. In order that these requirements may be complied with, certificates (Form 1001-A and Form 1071, Revised) will be provided by the Government and furnished to collectors of internal revenue for distribution to the public. Form 1001-A, as hereby revised, shall be in the following form: Form 1001-A FOREIGN ITEMS. Names must be (Revised) U. S. printed or Internal Revenue written plainly Ownership Certificate— Tax Not to Be Paid at the Source. (For the use of citizen or resident owners of stock of all foreign corporations, and citizen or resident owners of bonds of foreign countries or foreign corporations not having a paying agent in the United States.) Debtor Organization. Owner of Bonds or Stocks. Name Name Address Address (On line above give full description of foreign Item, date of dividend, or maturity of interest.) 1324 I certify that the owner of If owner is an individual, Is the bonds or stock upon which he married? the above-described income ac- jf ^ot, is he the head of a crued falls within the class of family' persons or organizations oppo- * rTTnM' site which such income is en- nmxTtro «f ^.L^i tered, and Is entitled to receive , O^NER. est dends the income reported without ^ ^\ ^"if^",, °^tt f^ i deduction of tax. gent of the United States, individual or fiduciary (Signature of owner or agent.) * — * — 2. Domestic or resi- ^^^^ corporation, as- Address sociation or partner- ship of agent ^ — ^ — Fiduciaries must enter under "Owner of Bonds or Stocks" the name of estate, trust er beneficiary on behalf of whom this certificate is made. If securities art owned joint- ly by several persona, one may sign, and the names, addresses, and proportion of ownership of each indorsed on the back hereof. NOTE. — The first licensed bank or collecting a«gent receiving this certificate is required to detach and forward it to the Com- missioner of Internal Revenue (Sorting Division), Washington, D. C, accompanied by a letter of transmittal showing the number of certificates and the aggregate amount of foreign items dis- closed thereon ; except that in the case of interest on bonds, the coupon accompanied by the proper ownership certificate shall be forwarded to the paying agent in this country, if one has been ap- pointed, and in cases where there is no such agent the csrtiflcate shall accompany the coupon to the last bank or collecting a«gent handling the item in this country. The certificate shall be de- tached by the paying agent and forwarded to the Commissioner of Internal Revenue with a letter of transmittal. If the debtor has no paying agent in this country, the last bank or collecting agent handling the interest item shall detach the certlllcate and forward same to the Commissioner of Internal Revenue in the same manner as prescribed in the case the first licensed bank or collecting agent is the source. When the certificate is detached by the first licensed bank or collecting aigent such bank or agent shall indorse upon the foreign item, "Certificate detached and in- formation furnished" (Name and address of licensee.) Date Treasury Decision 2716, and other rulings by this ofTiee in conflict herewith, are hereby superseded and repealed. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: October 2, 1918. L. S. ROWE, Acting Secretary of the Treasury. 132S (T. D. 2762) Exemption of Interest on Liberty Bonds Held or Subscribed for by Trustees, Partnerships and Corporations Under Supplement to Second Liberty Bond Act — Treasury Department, Office cf Comiiiissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: Questions have arisen with regard to the exemption of in- terest on bonds held or subscribed for by trustees, partner- ships or corporations under Section 1 of the Supplement to Second Liberty Bond Act, approved September 24, 1918. This section is as follows: That until the expiration of two years after the date of the termination of the war between the United States and the Imperial German Government, as fixed by proclama- tion of the President — (1) That interest on an amount of bonds of the Fourth Liberty Loan the principal of which does not exceed $30,000, owned by any individual, partnership, associa- tion, or corporation, shall be exempt from graduated addi- tional income taxes, commonly known as surtaxes, and excess and war-profits taxes, now or hereafter Imposed by the United States, upon the income or profits of indi- viduals, partnerships, associations, or corporations; (2) The interest received after January 1, 1918, on an amount of bonds of the First Liberty Loan Converted, dated either November 15, 1917, or May 9, 1918, the Second Liberty Loan, converted and unconverted, and the Third Liberty Loan, the principal of which does not exceed $45,000 in the aggregate, owned by any individual, part- nership, association, or corporation, shall be exempt from such taxes : Provided, however, That no owner of such bonds shall be entitled to such exemption In respect to the interest on an aggregate principal amount of such bonds exceeding one and one-half times the principal amount of bonds of the Fourth Liberty Loan originally subscribed for by such owner and still owned by him at the date of his tax return ; and (3) The Interest on an amount of bonds, the principal of which does not exceed $30,000, owned by any indi- vidual, partnership, association, or corporation, Issued upon conversion of 3% per centum bonds of the First Liberty Loan in the exercise of any privilege arising as a consequence of the issue of bonds of the Fourth Liberty Loan, shall be exempt from such taxes. The exemption provided in this section shall be In addi- tion to the exemption provided in section 7 of the Second Liberty Bond Act In respect to the Interest on an amount of bonds and certificates, authorized by siich Act and amendments thereto, the principal of which does not ex- ceed In the aggregate $5,000, and in addition to all other exemptions provided In the Second Liberty Bond Act. The exemptions authorized by subdivisions 1 and 3 of thif Section are conferred by reason of the ownership of bond therein referred to, while the exemption authorized by sub- division 2 is a collateral exemption conferred upon the bonds therein referred to by reason of the original subscription for and continued holding of Fourth Liberty Loan Bonds. (1) Trusts. — When income as such is taxable to bene- ficiaries, as in the case, under the present income tax law, of a trust the income of which is to be distributed annually or regularly between existing beneficiaries, each beneficiary is regarded as the owner of a proportionate part of the bonds held in trust and is entitled to exemption on account of such ownership as if he owned such proportionate part of the bonds 1326 directly. In such a case a subscription by a trustee for bonds of the Fourth Liberty Loan constitutes each beneficiary exist- ing at the time of such subscription an original subscriber for his proportionate part of such bonds and entitles such beneficiary, to the collateral exemption of interest on bonds of previous issues, whether owned by such beneficiary or by the trustee, as if the beneficiary had himself originally sub«cribed for such proportionate part of the bonds, and a subscription by such beneficiary for bonds of the Fourth Liberty Loan entitles him to the collateral exemption of interest on bonds of previous issues held by the trustees. When income is tax- able to the trustee, as in the case, under the present income tax law, of a trust the income of which is accumulated for the benefit of unborn or unascertained persons, the trustee is regarded as the owner of all the bonds held in trust and the trust is entitled to exemption on account of such ownership. In such a case a subscription by a trustee constitutes the trustee as such the original subscriber and entitled the trust, on account of such subscription, to the collateral exemption of interest on bonds of previous issues. (2) Partnerships. — ^When income of a partnership is taxable to the individual partners, as under the present income tax law, each partner is treated as the owner of a proportionate part of the bonds held by the partnership and entitled to exemption on account of such ownership as if such partner owned such proportionate part of the bonds directly. When the income of a partnership is taxable to the partnership as such, as under the present excess profits tax law, the partner- ship is treated as the owner of the bonds held by it and entitled to exemption from taxes assessed upon the income of the partnership as such. With reference to a tax assessed upon an individual partner on his share of the partnership income such partner, if a partner at the time of the original subscription by the partnership for bonds of the Fourth Liberty Loan, is treated as an original subscriber for a pro- portionate part of such bonds subscribed for by the partner- ship and as entitled to the collateral exemption of interest on bonds of previous issues on account of such original sub- scription for bonds of the Fourth Liberty Loan, as if he had subscribed directly for such proportionate part of the bonds. With reference to a tax assessed to the partnership upon the partnership income as a whole such partnership is the original subscriber and entitled to the collateral exemption of interest on bonds of previous issues on account of such original sub- scription for bonds of the Fourth Liberty Loan. (3) Corporations. — Income of a corporation as such is tax- able to the corporation and is not taxable to the stockholders. The corporation, and not the stockholders, is regarded as the owner of the bonds held by the corporation and entitled to exemption on account of such ownership. When bonds of the Fourth Liberty Loan are subscribed for by the corpora- tion it, and not the stockholders, is the original subscriber and entitled to the collateral exemption of interest on bonds of previous issues on account of such original subscription. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: October 18, 1918. P. 0. LEFFINGWELL, Acting Secretary of the Treasury. 1337 (T. D. 2763) Tax on Undistributed Net Income of Corporations, Joint- Stock Companies and Associations, and Insurance Com- panies — Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned : The following rulings with respect to the tax on undis- tributed income imposed by Section 10(b) added to Title I of the Revenue Act of September 8, 1916, by Section 1206 of Title Xn of the War Revenue Act of October 3, 1917, are additional to the rulings contained in Treasury Decision 2736. 1. Undistributed Net Income Subject to Tax. — In determin- ing the amount of net income of the taxable year "remaining undistributed" six months after its close, and not "invested and employed in the business," there may in general be subtracted the amount of any interest paid by the corporation but not allowed to be deducted for income tax purposes, and also the amount of contributions properly made for charitable or war purposes. 2. Use of Balance Sheets to Show Employment of Undis- tributed Net Income. — A corporation unable to show by tracing into particular assets or into the decrease of particular liabili- ties, the employment of undistributed net income in the business, is permitted to claim a benefit of what may be shown by a balance sheet for the date of the expiration of six months after the taxable year, or by a comparative balance sheet as indicated below. Thus, if the balance sheet for the date of the expiration of the six months period shows that the entire surplus and undivided profits of the corporation are represented by assets pertaining directly to the business, such as plant, equipment, inventories and accounts receivable, with only such amount represented by cash and by salable securities as is reasonably necessary for working capital or other established business requirements, the inference would seem warranted that the undistributed net income for the taxable year has been employed either for an increase in assets needed for the business or for a reduction of the business liabilities. It is therefore suggested that corporations unable to estab- lish through tracing into particular assets or into the decrease of particular liabilities the use of undistributed net income for employment in the business, may submit a comparative balance sheet showing in reasonable detail the assets and liabilities of the corporation as at the opening and the close of the taxable year and as at the close of the six months period. 3. Net Income of a Corporation During the Six Months Period. — If resort is made to the balance sheet in the effort to show the employment in the business of all undistributed net income of the taxable year or its retention for the reason- able requirements of the business, the net income for the six months after the taxable year is necessarily to be taken into account and it must be shown that the undistributed net income of the taxable year as well as the undistributed net income of the six months is so employed or retained. 1328 4. Distribution of Current Earnings Designated for Particu- lar Investments.— Paragraph 12 of T. D. 2736 referring to the statement that corporations may designate from what earn- ings an investment is made is not to be taken as in any manner altering the rule relative to the order in which earnings are to be treated and distributed as dividends under the provisions of Section 31(b) of the Act of September 8, 1916, added by Section 1210 of the Act of October 3, 1917. It is there specified that any distribution made to shareholders shall be deemed to have been made from the most recently accumulated undivided profits or surplus. The application of this provision is dealt with in T. D. 2659 and T. D. 2768. While a corporation retains profits without distribution of dividends, it may retain them in such form as it may elect, but when it makes any distribution of dividends the distri- bution must be treated as made from the most recent profits or surplus regardless of any previous designation of any portion of such earnings for investment purposes. The desig- nation of an investment in obligations of the United States issued subsequent to September 1, 1917, may serve to prevent the application of the additional tax of ten per cent to the amount so invested, but it does not warrant the disregarding of the amount of net income for the taxable year so invested in determining the profits or surplus from which any dividends may be distributed. DAKIEL C. ROPER, Commissioner of Internal Revenue. Approved: October 21, 1918. W. G. McADOO, Secretary of the Treasury. (T. D. 2770.) The time of notification to an executor of the amount of "excess" estate tax due is the date on which notice thereof is received by the executor. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: Section 207 of the Estate Tax Law, Title II of the Act of September 8, 1916, provides in part as follows: "That the executor shall pay the tax to the collector or deputy collector. If for any reason the amount of the tax cannot be determined, the payment of a sum of money sufficient, in the opinion of the collector, to discharge the tax shall be deemed payment in full of the tax, except " as in this section otherwise provided. If the amount so paid exceeds the amount of the tax as finally determined, the Commissioner of Internal Revenue shall refund such excess to the executor. If the amount of the tax as finally determined exceeds the amount so paid the Com- missioner shall notify the executor of the amount of such excess. From the time of such notification to the time of the final payment of such excess part of the tax, in- terest shall be added thereto at the rate of ten per centum per annum, and the amount of such excess shall be a lien upon the entire pross estate, except such part thereof as may have been sold to a bona fide purchaser for a fair consideration in money or money's worth." 1329 The question has arisen under this section as to what is the "time of such notification" from which interest is to be computed. The "time of such notification" is the date on which notice of the amount of such "excess part of the tax" ia received by the executor, whether such notice is given by mail or otherwise. All regulations and rulings inconsistent herewith are modi- fied accordingly. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: November 6, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2771.) Conditions under which taxes on real and personal prop- erty, and on income, are deductible in computing the net estate of a decedent for purposes of taxation under Title II of the Act of September 8, 1916. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue, Internal Revenue Agents and Others Concerned: The Eitate Tax Law (Act of September 8, 1916, Section 203a) permits the deduction of "administration expenses," "clairoa against the estate" and "charges against the estate," in determining the value of the net estate. Where the State sts.tus makes the tax a lien against property, it is deductible ao a "charge against the estate." Where it is a personal obligation of the taxpayer, it is deductible as a "claim against the estate." Taxes are never deductible as "administration expenses." In certain jurisdictions taxes, upon both real and personal property, are assessed prior to the expiration of the period for which the tax is laid; payment is not required until a date subsequent to the assessment; and the tax liability is created as of a date prior to the performance by the tax officers of all of their duties, such as determining the exact amount to be assessed to the taxpayer, and giving him notice of the tax. The rule for determining deductibility, in these and other cases, is as follows: If the tax liability is created as of a date in the lifetime of the decedent, the whole tax is deductible, although the entire period for which the tax is laid has not elapsed, its exact amount is not then ascertain- able, and payment is not required until a later date. On the other hand, if the tax liability is created as of a date subse- quent to the decedent's death, no part of it is deductible, although part of the period for which the tax is laid elapsed in the decedent's lifetime. The foregoing rules also apply to taxes on income, whether imposed by State statute or Act of Congress. Where the statute creates either a lien or personal obligation, as of a date in the decedent's lifetime, the tax is deductible. Where the lien or obligation is created as of a date subsequent to the decedent's death, the tax is not deductible. 1330 The Income and Excess Profits Taxes imposed by the Acts of September 8, 1916, and October 3, 1917, constitute personal obligations of the taxpayer, and are deductible in accordance with these rules. All unpaid taxes for years prior to that in which the decedent died are deductible. For the year in which the decedent died, the tax upon income up to the date of death is deductible. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: November 8, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2772.) Securities such as shares of stock in domestic corporations which are property within the United States within the meaning of Section 202, Title II of the Act of September 8, 1916, belonging to a non-resident decedent and de- posited with the British Treasury, for which certificates of deposit were issued, are subject to estate tax on the death of such non-resident decedent if the certificates have not previously been transferred. Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue, Internal Revenue Agents and Others Concerned: Estate tax is imposed by Title II of the Act of September 8, 1916, upon all property of a non-resident decedent situated in the United States. (See Sections 201, 202, 203, 205. Sec- tion 202 provides that "for the purposes of this title, stock in a domestic corporation owned and held by a non-resident decedent shall be deemed property within the United States." The question has been considered whether if such stock in a domestic corporation, or other security which if owned by a non-resident decedent would be property within the United States, is deposited with the British Treasury and a certificate of deposit is issued therefor such stock or other property is upon the death of the certificate holder a part of his gross estate and subject to estate tax. The holder of the certificate of deposit is the beneficial owner of the stock or other property for which such certifi- cate is issued. The relation of the British government to a certificate holder is substantially, if not technically, that of a trustee to a beneficiary. Upon the death of the beneficiary of a trust a transfer subject to estate tax takes place with reference to property within the United States held upon trust for such beneficiary. This is true even though the equitable title to such stock passes without the recording of the trans- fer upon the books of the corporation. For the purpose of the estate tax no distinction is to be taken between the rights of a deceased certificate holder and the rights of a deceased beneficiary of a trust of which an individual or corporation is trustee. It is held, therefore, that securities such as shares of stock 1331 in domestic corporations which are property within the United States within the meaning of Title II of the Act of September 8, 1916, deposited by an individual not resident within the United States with the British Treasuiy, and for which cer- tificates of deposit were issued, are at the death of such non- resident, if such certificates have not been transferred, a part of his gross estate and subject to estate tax. DANIEL C. ROPER, Commissions of Int«mal R«v«nua. Approved: November 8, 1918. L. S. ROWE, Acting Secretary of the Treasury. (T. D. 2773.) Special Excise Tax on Corporations — Decision of Court. A steamship company is entitled to deduct from gross income in annual tax returns required by action 88 of the act of Aujust 5, 1909 (36 Stat., 118), amounts paid out for ordinary and nectssary repairs in the maintenance and operation of its business and property and in addition a reasonable allowance for depreciation of property, if any Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States District Court for the Southern District of the Northern Division of Cali- fornia, in the case of the San Francisco & Portland Steamship Co. vs. John J. Scott, collector, is published for the informa- tion of internal revenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: November 8, 1918. L. S. ROWE, Acting Secretary of the Treasury. In the District Court of the United States for the Southern Division of the Northern District of California, Second Division. No. 15,782. The San Francisco & Portland Steamship Co., plaintiff, vs. John J. Scott, collector of internal revenue, etc., and August F. Muenter, defendants. (Memorandum by Bean, District Judge, sitting by special assignment.) This action is to recover certain amounts paid by the plain- tiff under protect as excise taxes levied under the act of Congress August 5, 1909, section 38 (36 Stat. L., 112) for the years 1910 and 1912. In its returns plaintiff included in its deductions for ordi- nary and necessary expen.ses paid out for the maintenance and operation of its business and property, for the year 1910, $17,088.77 and for the year 1912, $25,371.40, being amounts 1332 •xpended in each of such yearg for making "ordinary and necessary" repairs to the deck department, engine department, and commissary department of its steamers, and also $59,642.11 for 1910, and $79,350.96 for 1913 for depreciation of such steamers, being 5 per cent, of the book value thereof. It is admitted that the deductions for depreciation are rea- sonable and should be allowed, but the commissioner ruled that the cost of making ordinary and necessary repairs was not a proper item to be included in the operation and main- tenance expenses but was covered by the deductions for de- preciation and required plaintiff to pay taxes thereon, which it did under protest and hence this suit. The question thus raised does not seem to have been directly decided in any reported case to which my attention has been called or which I have been able to find, although the cost of repairs and upkeep was assumed in Grand Rapids and Indiana Railway vs. Doyle (245 Fed., 792) to be an item prop- erly included in operating and maintenance expense. Under the law the tax is to be laid on net income and such net income is to be ascertained by deducting from the gross income (1) all the ordinary and necessary expenses actually paid within the year out of income in the "maintenance and operation" of the business and property; (2) losses actually suffered not covered by insurance, including a reasonaoie allowance for depreciation, if any. « » * It will thus be seen that the deductions allowed are to include not only ordinary and necessary amounts actually paid out in the operations of the property but also the amounts paid out in the maintenance thereof, and in addition a rea- sonable sum for depreciation, if any. Now, th? operation of a business or property includes payment for labor and ma- terials which go into the actual operation thereof, while main- tenance means the upkeep or preserving the condition of the property to be operated and therefore, in my judgment, in- cludes the cost ordinary repairs necessary and proper from time to time for that purpose. Depreciation as used in the statute is not to be confused with ordinary repairs. It is intended to cover the estimated lessening in value of the orig- inal property, if any, due to wear and tear, decay, or gradual decline from natural causes, inadequacy, obsolescence, etc., which at some time in the future will require the abandon- ment or replacement of the property in spite of ordinary cur- rent repairs. It follows that the tax complained of was illegally exacted and the plaintiff is entitled to judgment for its recovery. Findings may be prepared accordingly. (T. D. 2778.) Instructions relative to acceptance of certificates of indebted- ness for income and profits taxes — Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. To Collectors of Internal Revenue and Others Concerned: Collectors of Internal Revenue are directed to receive at par United States Treasury certificates of indebtedness of the Tax Series of 1919, dated August 20, 1918, and maturing July 1333 15, 1919, and of Series T, dated November 7, 1918, and matur- ing March 15, 1919, in payment of income and profits taxes when payable at or before the maturity of the certificates. The amount, at par, of the Treasury certificates of indebted- ness presented by any taxpayer in* payment of income and profits taxes must not exceed the amount of the taxes to be paid by him. Deposits of certificates of indebtedness must be made by collectors with the Federal Reserve Banks of the districts in which the respective collectors' offices are located. Such certificates of indebtedness may be accepted by the col- lector prior to the date the tax is due and in that case should be forwarded by the collector to the Federal Reserve Bank to be held for account of the collector until the date the tax is due and for deposit on such date. Certificates of indebted- ness should be stamped as follows by the collector and when so stamped transmitted to the Federal Reserve Bank by reg- istered mail uninsured: , 191—. This certificate has been accepted in payment of income and profits taxes and will not be redeemed by the United States except for credit of the undersigned. Collector of Internal Revenue for the district of Each unmatured coupon attached to each such certificate ot indebtedness must be stamped across the face by the collector as follows: "Paid." All coupons maturing on or before the date the tax is due must be detached by the taxpayer and collected in ordinary course; but all other coupons must be attached to the certifi- cates and forwarded to the Federal Reserve Bank. Any accrued interest to the date the tax is due not covered by coupons detached as above provided will be remitted to the taxpayer by the Federal Reserve Bank by check and the col- lector must furnish to the Federal Reserve Bank the name and address of the taxpayer, the amount and serial numbers of the certificates presented in each case, the date of issue of the certificates, and the date the tax was due. Col- lectors shall in no case pay interest on such certificates nor accept them for an amount other or gi-eater than their face value. Receipts given by collectors to taxpayers should show the amount of certificates of each series received in payment of taxes. The collectors should make in tabular form a schedule in duplicate of the certificates of indebtedness to be sent to the Federal Reserve Bank, showing the serial number of each cer- tificate, date of issue, and face value. Certificates of indebted- ness accepted prior to the date the tax is due must be sched- uled separately, and such date must appear on the schedule. At the bottom of the schedule there should be written or stamped "Income and Profits Taxes $ ," which must agree with the total shown on the schedule. Such income and profits tax deposits must in all cases be shown on the face of the certificate of deposit (National Bank Form 15), separate and distinct from the item of miscellaneous internal revenue collections (formerly called Ordinary), but it is not necessary to give the separation into corporation income, individual in- come and profits taxes. One copy of this schedule must ac- company the certificates sent to the Federal Reserve Bank, and the other be retained by the collector. 1334 Until certificates of deposit are received from the Federal Reserve Banks, the amounts must be carried as cash on hand, and not credited as collections, as the dates of certificates of deposit determine the dates of collections. For the purpose of saving taxpayers the expense of trans- mitting such certificates as are held in Federal Reserve cities to the off"ice of the collector in whose district the taxes are payable, taxpayers desiring to pay income and profits taxes by Treasury certificates of indebtedness acceptable in payment of such taxes, should communicate with the collector of the district in which the taxes are payable and request from him authority to deposit such certificates with the Federal Re- serve Bank in the city in which the certificates are held. Collectors are authorized to permit deposits of Treasury cer- tificates of indebtedness in any Federal Reserve Bank with the distinct imderstanding that the Federal Reserve Bank is to issue a certificate of deposit in the collector's name covering the amount of the certificates of indebtedness at par and to state on the face of the certificate of deposit that the amount represented thereby is in payment of income and profits taxes. The Federal Reserve Bank should forward the original certifi- cate of deposit to the Treasurer of the United States, with its daily transcript, and transmit to the collector the duplicate and triplicate, accompanied by a statement giving the name of the taxpayer for whom the payment is made in order that the collector may make the necessary record and forward the duplicate to this oflfice. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: December 11, 1918. W. G. McADOO, Secretary of the Treasury. (T. D. 2783) INCOME TAX ACT OF OCTOBER 3, 1913— DECISION OF THE SUPREME COURT. 1. Taxability of Dividends from Subsidiary Corporations. Where a holding company owns all the stock of its subsidi- ary corporations except the qualifying shares of the directors, and the subsidiary corporations together with the holding company constitute a single enterprise, the accumulated earn- ings and surplus of the subsidiary corporations used by them as capital prior to January 1, 1913, do not become taxable income of the holding company when formally transferred to it as dividends. 2. Effect of the Decision. Though the holding company did not itself do the business of its subsidiaries and have possession of their property as in the Southern Pacific Company v. Lowe (247 U. S. 330) (T. D. 2730), the principle of that case governs. 3. Judgment Reversed. The judgment of the Circuit Court of Appeals (245 Fed. 1) (T. D. 2542) is reversed. 1335 Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C. The appended decision of the United States Supreme Court in the case of the Gulf Oil Corporation, petitioner, v. C. G. Lewellyn, Collector of Internal Revenue for the 23rd District of Pennsylvania, is published for the information of Internal Reyenue officers and others concerned. DANIEL C. ROPER, Commissioner of Internal Revenue. Approved: January 7, 1919. CARTER GLASS, Secretary of the Treasury. SUPREME COURT OF THE UNITED STATES. No. 310— October Term, 1918. On Writ of Certiorari to the United States Circuit Court of Appeals for the Third Circuit. Gulf Oil Corporation, Petitioner, vs. C. G. Lewellyn, Collector of In- ternal Revenue for the Twenty- third District of Pennsylvania. (December 9, 1918.) Mr. Justice HOLMES delivered the opinion of the Court. This is a suit to recover a tax levied upon certain dividends as income, under the Act of October 3, 1913, c. 16, Section II 38 Stat. 114, 166. The District Court gave judgment for the plaintiff, 242 Fed. Rep. 709, but this judgment was reversed by the Circuit Court of Appeals. 245 Fed. Rep. 1, 158. C. C. A. 1. The facts may be abridged from the findings below as follows. The petitioner was a holding company owning all the stock in the other corporations concerned except the qualifying shares held by directors. These companies with others constituted a single enterprise, carried on by the petitioner, of producing, buying, transporting, refining and selling oil. The subsidiary companies had retained their earnings, although making some loans inter se, and all their funds were invested in properties or actually required to carry on the business, so that the debtor companies had no money available to pay their debts. In January, 1913, the f)etitioner decided to take over the previously accumulated earn- ngs and surplus and did so in that year by votes of the com- panies that it controlled. B\jt, disregarding the forms gone through, the result was merely that the petitioner became the holder of the debts previously due from one of its companies to another. It was no richer than before, but its property now was represented by stock in and debts due from its sub- sidiaries, whereas formerly it was represented by the stock alone, the change being effected by entries upon the respective companies' books. The earnings thus transferred had been accumulated and had been used as capital before the taxing year. Lynch v. Turrish, 247 U. S. 221, 228. We are of opinion that the decision of the District Court was right. It is true that the petitioner and its subsidiaries were distinct beings in contemplation of law, but the facts that they w^ere related as parts of one enterprise, all owned by the petitioner, that the debts were all enterprise debts due to members, and that the dividends represented earnings that had been made in former years and that practically had been con- verted into capital, unite to convince us that the transaction should be regarded as bookkeeping rather than as "dividends declared and paid in the ordinary course by a corporation." Lynch v. Hornby, 247 U. S. 339, 346. The petitioner did not Itself do the business of its subsidiaries and have possession of their property as in Southern Pacific Co. v. Lowe, 247 U, S. 330, but the principle ot that case must be taken to cover this. By Section II, G, (c), 38 Stat. 174, and S. id. 202, the tax from January 1 to February 28, 1913, is levied as a special excise tax, but in view of our decision that the dividends here con- cerned were not Income it is unnecessarv to discuss the further question that has been raised under the latter clause as to the effect of the fact that excise taxes upon the subsidiary corpora- tions had been paid. Judgment reversed. Clerk Supreme Court, U. S. A true copy. Test: 1336 (I. T.— CIS. Mim. 1795.) Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, February 26, 1918. To Collectors of Internal Revenue: In order to complete claim* for the refunding of income tax collected under the Act of October S, 1913, on stock dividends; that is, claims based upon the decision of the Supreme Court in the case of Towne vs. Eisner, the following evid«nca is required : An affidavit showing — 1. The name of the corporation which declared and paid the stock dividend. 3. The date of declaration of the stock dividend and date of receipt by claimant. 3. In which year's return of annual net income did the claimant include this stock dividend? 4. Under what item on the return was the value of the stock dividend included, and what was the valuation placed upon the dividend in the return? 5. Has the stock thus received and returned as a dividend been sold by the claimant, and if so, what was the date of sale; how much did claimant receive from the sale; and what part of the total amount received from the sale was included by the claimant in its re- turn of annual net income for the year in which the sale occurred? 6. Did the dividend consist of stock of the corporation dis- tributing the dividend to claimant, or did it consist of stock acquired by the distributor in another cor- poration ? ITote. — ^A stock dividend is a distribution by a corporation to its stockholders of capital stock of the distributing cor- poration. A distribution of capital stock other than that of the distributing corporation is not a stock dividend but a dividend in property. The receipt on Form No. 1 should also be filed with the claim. In giving publicity to this requirement please inform tax- payers that there is no possible advantage in the employment of special attorneys for the prosecution of claims. Prepara- tions are being made for the prompt handling of these cases and it is believed that they can be disposed of with minimum delay and inconvenience to the taxpayer. Claims filed directly by the claimants will receive in every respect as careful and expeditious consideration as those filed through special attorneys. DANIEL C. ROPER, Commissioner, (I. T. MIM. 1866.) Treasury Department, Office of Commissioner of Internal Revenue, Washington, D. C, April. 23, 1918. To Collectors of Internal Revenue: The attention of collectors is directed to the printed in- structions contained on monthly return Form 1012, Revised, 1337 1918, to the effect that "each class of payments must be listed and totaled separately under the heading A, B, C or D." This office has received many monthly returns on which there have been listed by debtor corporations and withholding agents payments of interest falling within the above classes which have not been segregated as required. Returns pre- pared in this manner can not be satisfactorily audited by this office. The co-operation of organizations required to file monthly returns is desired, and their observance of all in- structions in this connection will, in the opinion of this office, not only serve to keep their own records more clearly, but will facilitate the audit of such returns. This office will hereafter require that monthly returns on Form 1012, Revised, be rendered by debtor corporations and withholding agents strictly according to the printed instruc- tions appearing thereon. Collectors of Internal Revenue are instructed, therefore, that they shall return to the debtor cor- poration or withholding agent concerned, any monthly returns on Form 1013, Revised, filed subsequent to the receipt by them of this letter, which are not rendered in accordance with the procedure outlined above, and require such debtor corporation or withholding agent to file amended returns. DANIEL C. ROPER, Commissioner. Bonds Containing Tax-Free Clause, and Certificate to be Filed on or Before February 1st — Treasury Department, Washington, D. C, February 26, 1918. Standard Statistics Co., Inc., 47-49 West St., New York, N. Y. Sirs: Receipt is acknowledged of your communication dated Jan- uary 16, 1918, referring to the provisions of subdivision (c) of Section 9 of the Act of September 8, 1916, as amended, and requesting that in view of the considerable difference of opinion which exists as to the interpretation placed upon the provision thereof, you be advised whether the construc- tion placed thereon is as follows: "Where bonds contain a tax-free clause, will it be neces- sary for the corporation to actually withhold the tax on an amount in excess of the exemption claimed or does the cor- poration pay the interest in full to the bondholder and as- sume the liability for the payment of the tax. Relative to the certificate to be filed with the withholding agent on or before February first, in order to receive the benefit of ex- emption, is this interpreted to mean that if an individual entitled to an exemption of $2,000 and has income equivalent to this amount, derived entirely from tax-free bonds will have the tax deducted by the corporation, if a certificate is filed not claiming exemption, or whether the individual is privileged to substitute an exemption certificate for non- exemption certificate up until February first of the follow- ing year, during which the income was earned?" In reply you are advised that under the provisions of the section mentioned, there is imposed upon the debtor corpora- 1338 tion or its duly accredited withholding agent the liability for the deduction, withholding and payment of the 2% normal tax from all interest payments made to citizens and aliens, both resident and non-resident, upon bonds, containing a tax- free clause made to the obligees on and after January 1, 1917, and a like tax of 6% on all such payments made to foreign corporations having no place of business in the United States, after October 3, 1917. If an individual has an income of the amount in the in- stance cited by you and files a certificate claiming no ex- emption, the debtor corporation will be held liable for the withholding of the normal tax on the full amount of the interest payment due. If, however, the individual, at any time prior to February 1st, of the year following during which the income was paid, substitutes for the certificate previously filed, one claiming exemption, the debtor corpora- tion will not be required to withhold tax an any amount not in excess of the exemption claimed. Respectfully, L. F. SPEER, Deputy Commissioner. Wife's Income Prior to Marriage to be Included in Husband'i Return. Treasury Department, Washington, February 28, 1918. Mr. C. H. Hubbell, Tax Consultant, First National Bank, Cleveland, Ohio. Sir:— Reference is made to your letter of the 6th instant in which you ask the manner in which an individual who was married during the year should render his income tax return. You state that the salary for the year of the individual amounted to $3,900.00, and that his wife earned during the year and prior to their marriage $700.00. You ask if the amount earned by the wife prior to her marriage should be included in the husband's return, and what exemption should be claimed by the husband. In reply you are advised that unless the wife has a separate estate which requires her to file a separate return of income, or to join her husband in a return which shall set forth her income separately, her husband should include in his return the income accruing to the wife from services rendered by her whether such income accrued prior or subsequent to their marriage. An exemption of $2,000.00 should then be taken by the husband. Respectfully, (Signed) L. F. SPEER, Deputy Commissioner. By courtesy of First National Bank, Cleveland, Ohio. 1339 March 13, 1918. DANIEL C. ROPER, Commissioner of Internal lleveniie, Washington, D. C. (INQUIRY.) We understand partnership income tax return, Form 1065, is required from domestic partnerships having $6,000 or more without deducting salaries or interest paid to partners. Are we to read paragraph 2, Partnership Excess Profits Tax Re- turn, Form 1102, as though the words six thousand dollars or more were followed by the phrase "without deducting sal- aries or interest paid to partners"? Is an individual having net income from trade or business three thousand dollars and from rents and dividends outside of his trade or business four thousand dollars required to make individual excess profits tax return? Please wire answer collect to Loudonville. FARMERS BANK, Loudonville, Ohio. (REPLY.) "Replying to your telegram March 14. If salary and inter- est payment covered Articles 32 and 33 Regulations 41 are fully explained on Form 1065; return on Form 1102 will not be required when partnership net income after deduction of salaries and interest is less than six thousand dollars unless specially called for. "In case of individual submitted by you he would not be required to file excess profits tax return unless the manage- ment of rental properties constitute a trade or business as defined by Article 8, Regulations 41, and the combined income from his several trades and businesses amounts to six thousand dollars or more." FLOOR TAX AS A DEDUCTION. Treasury Department, Washington, March 15, 1918. Mr. Chas. H. Hubbell, Tax Consultant, First National Bank, Cleveland, Ohio. Sir: Receipt is acknowledged of your letter of the 20th ultimo, m which you ask for information in behalf of the Wm. J. Gal- lagher Company, of Cleveland, Ohio. The information desired is in regard to the so-called floor tax on liquor imposed by Section 303 of the Act of October 3, 1917. You ask to be ad- vised whether such floor tax should be considered as a part of the cost of the goods, or should such tax be included as a deduction in arriving at the net income of the corporation. In reply you are informed that the floor taxes actually paid or set up as a liability as discussed hereinafter may be de- ducted from gross income as taxes paid. 1340 Floor taxes paid on specific articles under the provisiont of the Act of October 3, 1917, cannot be treated by the owner of the articles as a part of the cost of such articles. With reference to your inquiry in regard to any distinction to be made between floor taxes paid and floor taxet for which ft bond has been given, in the case of a concern keeping its books on an accrual basis, you are informed that a corpora- tion keeping accounts upon any other basis than that of actual receipts and disbursements may make its returns upon th» basis upon which its accounts are kept. It therefore follows that if a corporation which is subject to the tax imposed by Section 303 of the Act of October 3, 1917, keeps its accounts upon a basis other than actual receipts and disbursements, and its returns of annual net income are prepared in accordance with Treasury Decision 2433, it will be permitted to deduct, in its returns of annual net income for the year 1917 the amount of floor taxes assessed for that year, and for which it has given bonds as collateral for the payment of the tax to the Collector of Internal Revenue. If, however, the cor- poration prepares its returns upon the basis of actual receipts and disbursements, and not in accordance with Treasury De- cision 2433, it will not be permitted to deduct as taxes paid, in the return of annual net income for the year 1917, the taxes imposed by Section 303 of the Act of October 3, 1917, which taxes arc paid subsequent, to January 1, 1918. Respectfully, (Signed) DANIEL C. ROPER.. Commissioner. By courtesy of First National Bank, Cleveland, Ohio. March 19, 1918. Instructions Issued by the Alien Property Custodian In Relation to Income Taxes. By a Treasury Decision issued March 18 (T. D. No. 2673) all individuals, firms or corporations are to be governed as follows in respect to filing Federal income tax returns oi paying Federal income taxes under the Income Tax Act and the War Income Tax Act on any money or other property of enemies, as defined by the "Trading with the Enemy Act,** that has come or may come into their possession: I. For the Tear 1917. 1. Where money or other property has not yet been de- livered to the Alien Property Custodian, but is held subject to his order. In all such cases it is necessary to file returns of informa- tion and income in respect of all such money or other prop- erty for such period as may elapse prior to the actual delivery •f the money or other property to the custodian, and also to withhold and to pay the normal tax in respect of any income actually paid to or for any enemy prior to October 6, 1917, the date when the "Trading with the Enemy Act" became a law. 1341 2. Where the money or other property has actually been delivered to the Alien Property Custodian. Where the money or other property has actually been de- livered to the custodian, return of income is still required to be filed in due course in respect of all money or other property for the period that has elapsed up to the time of the actual delivery to the custodian, and payment of taxes is required to be made in cases, but only in such cases, where there has been withheld from what is actually delivered to the custodian the amount of the normal tax in respect of income actually paid over to or for the enemy prior to October 6, 1917. II. For the Year 1918 and Subsequent Years. Return of income is required to be filed in due course ^n respect of all money or other property for such part of the year 1918 or any subsequent year as may elapse prior to the actual delivery of the money or other property to the Alien Property Custodian, but no withholding or the payment ot any taxes is required. III. Requirements in respect to money or other property of enemies held or utilized under authority of licenses issued by the War Trade Board. Wherever money or other property is held or utilized unuer authority of a license issued by the War Trade Board, the obligation upon every individual, firm or corporation holding such license to withhold or return or pay income taxes for the duration of such license, is not affected in any way by this Treasury Decision. IV. Requirements in respect to depositaries and agents appointed by the Alien Property Custodian. Depositaries and agents appointed by the Alien Property Custodian to represent him in relation to any money or other property are not required to make any deductions, or to file any returns, or to make any payments in respect to any in- come taxes for the year 1917 or subsequent years on any money or other property that may come into their hands. The obligation, if any, to make the same rests, as above ex- plained, upon the individual, firm or corporation from whom the depositaries or agents receive the money or other property for the account of the Alien Property Custodian. V. Requirements as to licenses, ownership certificates, etc., for collection of coupons. Nothing in the above is to be construed as relieving any individual, firm or corporation from complying before col- lection of coupons for or on account of enemies with the requirments (1) of the War Trade Board in respect to license before such collection; (2) of the Alien Property Custodian in respect to any rules and regulations relatmg to such col- lection; (3) of the Federal Reserve Board in respect to regis- tration certificates; and (4) of the Internal Revenue Depart- ment in respect to ownership certificates to accompany such coupons. Of these requirements only the fourth applies to depositaries and agents appointed by the Alien Property Cus- 1342 todian. United States Internal Revenue Forms No. 1000 and No. 1001, as revised January, 1918, are to be used by such depositaries and agents in collecting coupons for the account of the Alien Property Custodian and such certificates are to be signed as follows: (Name of enemy) Trust. by (Alien Property Custodian Depositary.) Treasury Department, Washington, July 1», 1918. Tax on Undistributed Net Income — L. & A. U. Zinke, 290 Broadway, New York, N. Y. Sirs: Replying to your letter of the 11th instant, you are in- formed that a corporation having a fiscal year ended within the calendar year, 1917, which is required to file its return on Form 1112, should file such return with the Collector of Internal Revenue on or before August 1, 1918. A corporation which files its return on the basis of the calendar year is not required to file such return until sixty (60) days after the expiration of six months from the close of its taxable year. Therefore, in such a case the return Is not due until August 29, 1918. Respectfully, L. F. SPEER, Deputy Commissioner. By courtesy of L. & A. U. Zinke, New York. TAX CERTIFICATES, SERIES OF 1919— Announcement of the Secretary of the Treasury Relating to United States Treasury Certificates of Indebtedness, Re- ceivable for Income and Excess Profits Taxes. Dated August 20, 1918, Payable July 15, 1919—4% Interest- August 19, 1918. To the Banks, Trust Companies and the Public of the Fifth Federal Reserve District: "The Secretary of the Treasury under authority of Act approved September 24, 1917, as amended by Act approved April 4, 1918, offers for subscription at par and accrued in- terest Treasury Certificates of Indebtedness of the United States, tax series of 1919, dated and bearing interest from 1343 August 20, 1918, payable July 15, 1919, bearing interest at the rate of 4% per annum. Applications will be received at the Federal Reserve Banks. Subscription books will close at close of business August 30, 1918. Bearer certificates with interest coupons attached will be issued in denominations of $500, $1,000, $5,000, $10,000 and $100,000. Tax Exemption Features. — Said certificates shall be exempt both as to principal and interest from all taxation now or hereafter imposed by the United States, any State or any of the possessions of the United States, or by any local taxing authority, except: (a) Estate or inheritance taxes, and, (b) Graduated additional income taxes, commonly known as surtaxes, and excess profits and war profits taxes now or hereafter imposed by the United States upon the income or profits of individuals, partnerships, associations or corpora- tions. (They carry exemptions from the increased income taxes that are in contemplation by Congiess.) The interest on an amount of bonds and certificates au- thorized by said Act, approved September 24,^1917, or by said Act as amended by said Act approved April 4, 1918, or by the Act approved July 9, 1918, the principal of which does not exceed in the aggregate $5,000 owned by any individual, partnership, association or corporation, shall be exempt from the taxes provided for in clause (b) above. Receivable in Payment of Income and Excess Profits Taxes. — The certificates of this series will be accepted at par v.ith adjustment of accrued interest under rules and regulations to be prescribed by the Secretary of the Treasury, in pay- ment of income and excess profits taxes when payable at or before the maturity of the certificates. The certificates of this series do not bear the circulation privilege and will not be accepted in payment on bond sub- scriptions. The right is reserved to reject any subscription and to allot less than the amount of certificates applied for, and to close the subscriptions at any time without notice. Time of Payment. — Payment at par ana accrued interest for certificates allotted must be made on allotment. After allotment and upon payment Federal Reserve Banks will issue interim receipts pending delivery of the definitive certificates. Payment by Credit. — Qualified depositaries will be permitted to make payment by credit for certificates allotted to them for themselves and their customers up to an amount for which each shall have been qualified in excess of existing de- posits, when so notified by Federal Reserve Banks. (Application to become depositaries, or to increase the amount for which any bank or trust company may have been designated as a depositary, will be received and promptly acted upon.) As Fiscal Agents of the United States, Federal Reserve Banks are authorized and requested to receive subscriptions and to make allotment in full in the order of the receipt of subscriptions until further notice. 1344 I Certificates of series IV-A, IV-B, IV-C and IV-D will be accepted at par with an adjustment of accrued interest in payment for any certificates of the series now ofiered which shall be subscribed for and allotted not later than August 30, 1918." Respectfully, FEDERAL RESERVE BANK OF RICHMOND, Fiscal Agent of the United States. Office of Commissioner of Internal Revenue. Treasury Department. Washington, December 24, 1918. Standard Statistics Company, Inc., 47 West Street, New York City. Gentlemen : Reference is made to your letter of December 12, 1918, which is quoted as follows: "Under an unofficial ruling your office has held that the Government cannot accept payment of taxes by a corporation in behalf of a bondholder where such bond does not contain a tax-free covenant. "Corporation *A' issuing bonds without a tax-free cove- nant voluntarily pays its coupons at 102% of face valua for the purpose of reimbursing its bondholders for a por- tion of the normal tax assessed against income from interest. "Thus, bondholder 'B,' holding coupons to the face value of $1,000, receives $1,020 from the corporation. "Is the $20 extra received from the corporation income to the bondholder subject to tax, or should it be classitiea as a gift, the principal of which is exempt from tax?" In reply you are advised that if a corporation contracts with its bondholders to pay the income tax to be imposed on its bonds, and if such agreement is not embodied in the form of a "tax-free covenant" in such bonds, then any amount paid to the bondholders by virtue of such contract constitutes income for the year in which received. The contract so entered into is a bargain, as between the debtor corporation and its bond- holders, of which this office does not take cognizance. However, if there is no prior contract or agreement or under- standing in the matter and the corporation voluntarily re- imbursed its bondholders for a portion of the tax to be assessed against the income from interest, then the amount so received will be regarded as a gift to the bondholders, and the sum so paid will not be allowed as a deduction to the corporation. Respectfully, DANIEL C. ROPER, Commissioner. 1345 STOCK DIVIDENDS. Judge Julius M. Mayer, sitting in a test case in the United States District Court, decided without leaving the bench that the Supreme Court of the United States meant what it said in the famous Towne Case, and that stock dividends are no more subject to income tax under the 1916 Law than they were under the 1913 Law, which was the subject of the original de- cision. The Towne Case above referred to was the case of Towne vs. Eisner, in which the United States Supreme Court handed down a decision on January 7th, 1918. Under this decision it was held that a stock dividend declared by a corporation in January, 1914, was not taxable income. As the Act of October 3, 1913, was in effect for the years 1913-1914 and 1915; this decision only affected stock dividends paid within these years. The Income Tax Laws of September 8th, 1916, and October 3rd, 1917, as well as the present Revenue Bill about to be passed specifically tax stock dividends. If the decision handed down by Judge Mayer is upheld by the United States Supreme Court, it will mean that all taxes which have been paid upon stock dividends from January 1st, 1916, will have to be refunded to taxpayers upon the submis- sion of proper claims. The opinion in the above case consists merely of an endorse- ment on the demurrer, as follows : Demurrer overruled on the authority of Towne v. Eisner, 24.') U. S. 418— see also Peabody v. Eisner, 247 U. S. 347. JULIUS M. MAYER, District Judge. Tax on Undistributed Net Income of Corporations. The Act of September 8, 1916, as amended, Section 10(b), provides that — (b) In addition to the income tax imposed by subdivision (a) of this section there shall be levied, assessed, collected and paid annually an additional tax of ten per centum upon the amount remaining undistributed six months after the end of each calendar or fiscal year of the total net Income of every corporation, Joint- stock company or association, or insurance company, received during the year, as determined for the purposes of the tax im- posed by such subdivision (a), but not including the amount of any income taxes paid by It within the year imposed by the authority of the United States. The tax Imposed by this subdivision shall not apply to that portion of such undistributed net income which is actually In- vested and employed in the business or Is retained for employ- ment In the reasonable requirements of the business or is invested in the obligations of the United States Issued after September first, nineteen hundred and seventeen : Provided, That if the Sec- retary of the Treasury ascertains and finds that any portion of such amount so retained at any time for employment in the busi- ness is not so employed or is not reasonably required in the busi- ness a tax of fifteen per centum shall be levied, assessed, collected and paid thereon. The foregoing tax rates shall apply to the undistributed net income received by every taxable corporation, joint-stock com- pany, or association, or insurance company in the calendar year nineteen hundred and seventeen and in each year thereafter, ex- cept that if It baa fixed its own fiscal year under the provisions of existing law, the foregoing rates shall apply to the proportion of the taxable undistributed net Income returned for the fiscal year ending prior to December thirty-first, nineteen hundred and seventeen, which the period between January first, nineteen hun- dred and seventeen, and the end of such fiscal year bears to the whole of such fiscal year. The period of six months after the end of each calendar year referred to for corporations who closed their books on December thirty -first, nineteen hundred and seventeen, is from 1346 January first, nineteen hundred and eighteen, to June thir- tieth, nineteen hundred and eighteen. Domestic and foreign corporations with a taxable net income as shown by returns rendered for the year nineteen hundred and seventeen will be required to file a return of undistributed net income on Form 1112, as prescribed by the Government, and the time for filing this return is within sixty days after the expiration of six months (June 30, 1918) from the close of the last taxable year (that is, a calendar year or fiscal year, if diflferent from the calendar year). There will be a tax of ten per centum on the undistributed net income and a tax of fifteen per centum, if any portion of the net income of the taxable year reported to be retained for employment in the reasonable requirements of the busi- ness was not 80 employed. The time for the payment of the tax is ten days after the day of notice and demand of tax assessed. Otherwise there will be a penalty of five per centum of the amount thereof, plus one per centum interest per month that the tax remains unpaid. For failure to file the return within the time required fifty per centum penalty of the tax will attach and a penalty not to exceed ten thousand dollars. Returns in this connection may be had from the local internal revenue collector. STANDARD STATISTICS CO., Ipc Excess Profits Tax Primer. Prepared by the Bureau of Internal Revenue for the Information and Assistance of Taxpayers. GENERAL FEATURES. TAX APPLIES TO TRADE OR BUSINESS. In the case of a corporation or partnership the law ex- pressly provides (Sec. 201) that all its income, from what- ever source derived, shall be deemed to be received from its trade or business. In this case there is one business and one net income. In the case of an individual the excess profits tax applies only to that part of the net income which is derived from the taxpayer's trade, business, profession or occupation, even though the taxpayer may have other income subject to the ordinary income tax. Unlike a corporation or partnership, an individual may be engaged in two businesses, one with invested capital, one with no invested capital or only a nomi- nal capital. If he has more than one business with invested capital, they will all be regarded as one; and if he has more than one business with no invested capital, they will be re- garded as one. If he has both kinds of business, he will be regarded as having two businesses. It is an Income Tax. It is an income tax in addition to the regular income tax of September 8, 1916, as amended, and the war income tax of October 3, 1917. It is more than a tax on "war profits"; it 1347 reaches all income in excess of a stipulated normal deduc- tion. The tax falls into two classes: (a) An 8 per cent tax imposed by Section 209 upon trades or businesses having no invested capital or merely a nominal capital, e. g., doctors, lawyers, and professional or salaried persons in general. Domestic corporations under this sec- tion are allowed a specific deduction of $3,000; domestic part- nerships and individual citizens or residents a specific deduc- tion of $6,000. (See Articles 71-74 of Regulations No. 41.) (b) A graduated tax with rates rising from 20 to 60 per cent upon the net income in excess of a deduction equal to a percentage (varying from 7 to 9 per cent) upon invested capital, plus $6,000 in the case of an individual or partner- ship or $3,000 in the case of a corporation. Foreign corpora- tions or partnerships and non-resident aliens are not entitled to the specific deductions of $3,000 or $6,000, respectively. An exceedingly important sub-division under class (b) con- sists of those cases in which the invested capital — or the net income for the pre-war period — can not be satisfactorily de- termined. In such cases the assessm.ent is based largely upon conditions or relations existing among representative business concerns in a like or similar trade or business. (See Sections 205 and 210 of the law and Articles 18, 24 and 52 of Regulations No. 41.) Classification of Taxpayers. In the case of a corporation or partnership all of its income will be held to be of the same class as the income from its principal trade or business. There is one income and one tax. (Article 14 of Regulations No. 41.) In the case of an individual there may be income subject to the 8 per cent rate and income subject to the graduated rates, in which case there will be two deductions and two taxes — but not more than two. (See Articles 35 and 36 of Regulations No. 41.) In general, the taxpayer can not decide for himself whether he is subject to the 8 per cent tax or the graduated tax, but must fill out the ordinary form so far as possible in order that the department may decide into which class he properly falls. Exception, however, is made in the case of individuals whose income consists wholly of salary or the earnings of personal service and who employ no invested capital in their trade or business. In such cases the excess profits tax will be computed from the data on the income tax return. Form 1040. INCOME SUBJECT TO TAX— CORPORATIONS, PARTNER- SHIPS, AND INDIVIDUALS. 1. A partnership makes |S0,G00, one-fourth of which is paid to a special or sileat partner who takes no real part in th« ctnduct of the business. Is the partnership taxable with respect to the $20,000 paid to the silent partner? Yts. Th« partnership is engaged in business and is taxable upon its entire net income. However, no member of the partnership as an individual is subject to excess profits tax on his shart of the partnership profits. (See Article 41 of Regulations No. 41.) 8. A corporation has been making income tax returns on the basis of a fiscal year ending June 30. Net income for the last six months of 1916 was $1,000,000. The losses for the 1348 first six months of 1917 were $400,000. Is there any taxable income subject to excess profits tax for the year 1917? Yes. The profits for the full fiscal year were $600,000. One-half of the fiscal year falling in the calendar year 1917, the corporation will be taxable on a proportionate amount. The corporation should make a return for the full fiscal year, compute the tax that would ordinarily be due for an entire year, and then take a proportionate part (in this case one- half) as the tax to be paid. (See Article 19 of Rejfulations No. 41.) 3. Is a "Massachusetts tnist" taxed as a corporation or partnership? As a corporation. The term "corporation" includes joint- stock companies or associations, no matter how created or organized. (See Article 2 of Regulations No. 41.) 4. A. B., an attorney, bought a house and lot in June, 1917, received rent from it until October, 1917, and then sold it at a profit. Does he pay on rentals and the profit? An attorney, whose business is of a purely personal- service nature is taxable at 8 per cent under Section 209. He might buy real estate for investment and later sell it at a consider- able profit, but this being an isolated transaction and not a business, the income and profits therefrom would not be sub- ject to excess profits tax. He would be entitled to one de- duction of $6,000. 5. A lawyer with a considerable income from his practice, receives fees as director in two banks and an insurance com- pany. Are such fees taxable? Regular service as a director constitutes an occupation or business and the fees therefrom, along wdth the regular in- come of the lawyer from his practice, are taxable at 8 per cent under Section 209, with one deduction of $6,000. 6. A landlord renting a large farm on shares, which re- quires considerable attention, employs an agent to look after his interest, see that the farm buildings are kept in good repair, collect and market his share of the crops, etc. Is the rental taxable? Yes; at the graduated rates. The landlord is engaged in business with respect to the farm and the fact that he em- ploys an agent to look after his business does not relieve him frbm the tax nor entitle him to th« 8 per cisnt rate. 7. John Smith owns and operates a dry goods store. He also owns and operates a shoe store. Is he allowed to re- port these businesses separately with a separate deduction for each? No; the rule is that there may be one deduction for a busineBS with no invested capital or merely a nominal capital (personal service), and another deduction for an imrelated business having invested capital, but there may not be more than one deduction for businesses taxed under Section 201, or for businesses taxed imder Section 209. 8. I conduct two entirely separate businesses both employ- ing invested capital. Should I make a combined return for the two businesses, or a separate return for each ousiness? You should make one return covering the two businesses. 9. A contractor and dealer in real estate also lists property owned by others and does business as a real estate agent or broker. How is he taxed? 1349 These activities are so interrelated as to constitute one business. If the individual employs in this real estate busi- ness a considerable amount of capital he is taxable at the graduated rates under Section 201. 10. I am a doctor and also manage and direct a small fac- tory which I own. How am I taxed? You will pay a tax of 8 per cent on the fees from your medical practice under Section 209, and a graduated tax on the income from your factory. Under Section 209 you will get a deduction of $6,000; under Section 201 a specific deduction of $6,000 plus a percentage deduction of from 7 to 9 per cent on the capital invested in the factory. 11. A school teacher buys a farm upon which oil is dis- covered, and sells the farm at a large profit. Is such profit subject to excess profits tax? Not unless the teacher is also a farmer or buys and sells real estate with sufficient frequency to make the latter one of his occupations. The teacher may have an occupation or business other than teaching the profits from which would be taxable, but if he buys a farm simply as an isolated in- vestment and does not run it, the profits from its sale would not be subject to the tax. (See question 12.) 12. A manufacturer who has been in business for many years sells his factory at a considerable profit. Is such profit subject to excess profits tax? Yes; because the profit in this and similiar cases is a nor- mal result of winding up the business; it is part of the busi- ness. On the other hand, if the manufacturer had bought a farm and sold it at a profit, the profit would not — if the transaction were isolated — be taxable. Profit from an iso- lated transaction outside of his business is not taxable. Profit from an isolated transaction connected with his business is taxable. 13. I am a traveling salesman, working wholly on a com- mission basis. I earn $15,000. My traveling expenses are $3,000. My house advances me $6,000 per year, giving me the rest of my commissions at the end of the year. May I con- sider that I am in business and allow myself a salary of $6,000, leaving a profit of $6,000 for the business itself? In that case I should be entitled to a deduction of $6,000 for the business and $6,000 against my salary and I should have no excess profits tax to pay. No. You should enter the $15,000 in block A on Form 1040, making proper deduction for expenses. You would then have a net income of $12,000, of which $6,000 would be taxable at the 8 per cent rate. 14. An individual who received a salary of $8,000 during the taxable year has a minor son who earned $800 during the taxable year in a separate occupation. Must the $800 be in- cluded in the income of the parent subject to excess profits tax? No. The father is not engaged in business with respect to the income of his minor children earned in a separate and distinct occupation. DEDUCTIONS. 15. A corporation had a net income of $10,000 in 1911, $8,000 in 1912, and a loss of $2,000 in 1913. What is the "average amount of the annual net income of the trade or 1350 business during the pre-war period," for the purpose of de- termining the percentage deduction? Six thousand dollars ($18,000 divided by three). The loss of $2,000 is disregarded inasmuch as the income tax law does not permit the loss of one year to affect or reduce the profit of another year. 16. A firm commenced business April 1, 1911. What period should it use to determine its pre-war earnings and invested capital? All of the years 1912 and 1913. The year 1911 is disre- garded, as the law provides that only entire calendar years shall be counted. (See Section 200.) 17. What percentage deduction is given a taxpayer who started in business after January 1, 1913? Eight per cent of the invested capital. (See Section 204 of the law and Article 21 of Regulations No. 41.) 18. Jones was in the hardware business during the pre-war period. He made more than 9 per cent on his invested capital. In 1914 he sold the hardware business and established a fur- niture store and is making over 9 per cent. What percentage deduction does he get? ■ Eight per cent, since he is now carrying on a business in which he was not engaged during the pre-war period. How- ever, if he had bought an established furniture business hav- ing pre-war earnings of 9 per cent, he would be allowed 9 per cent, the business being a continuation of a business with pre-war experience. (See Section 204 of the law and Article 22 of Regulations No. 41.) 19. Smith bought a hotel business in 1914 which had been in existence during the pre-war period, but he is unable to ascertain what was its average invested capital for that period. What is his percentage deduction? He should compute the tax in the first instance on the basis of a 7 per cent deduction, but may file a claim (with explanation) for final assessment under the provisions of Sec- tion 210 (Articles 24 and 52 of Regulations No. 41), and if the Secretary of the Treasury is unable satisfactorily to de- termine the invested capital, the percentage deduction will be computed at the same rate per cent as in the case of rep- resentative individuals engaged in a like or similar business. 20. An individual is engaged in the manufacturing business. He makes annual contributions to a near-by hospital in which injured employes of his establishment are cared for. He also makes contributions to his church and to the public library. Is he allowed to deduct these contributions in computing his net income for purposes of the excess profits tax? The contributions to the hospital would constitute a proper deduction, since they have a reasonable connection with his business, and may be considered as coming from the business rather than from the individual in his personal capacity. Such contributions will be allowed up to 15 per cent of the income of the business. The contributions to the church and the library will be re- garded as made by the individual in his personal capacity and are not allowable deductions from the income of the trade or business for the purposes of the excess profits tax. (See Article 37 Regulations No. 41.) 1351 21. A partnership has been in the habit of making contribu- tions to various churches, local charities and the Y. M. C. A., and charging the amounts off to profit and loss at the end of the year. Will it be allowed to deduct these contributions in computing its net income for purposes of the excess profits tax? No. These contributions are not connected with the trade or business. The same rule applies in the case of a partnership as in the case of an individual. (See Section 206 of the law and Article 37 of Regulations No. 41.) 22. An incorporated department store occasionally con- tributes to local charities, hospitals, etc. Are these items de- ductible? No. Donations which do not have in them the element of compensation are considered gratuities and are not allowable deductions from gross income as an expense of operation or maintenance or under any other head. (See Articles 134 and 135, Regulations No. 33, Revised, governing the collection of the income tax.) 23. Several of our regular employes have enlisted in the serv- ice of the United States in different capacities, some in the Army, others in the Navy, Food Administration, etc. We have continued their salaries during their absence. May we charges these payments as expense in computing our profits? Yes. 24. Four other attorneys and mystelf conduct a law business under a partnership arrangement. There is no invested capital. It is our custom to distribute the entire net income to the partners as salaries, leaving the partnership no net profits. May we continue to do this? If the partnership makes a return it will be entitled to a deduction of $6,000 and the several partners are each entitled to the same deduction. In other words, if we make a separate return for the partnership there will be a total of six $6,000 deductions, whereas if all the net income is distributed and taxed to the individual partners there will be only five such deductions. In the latter case the Government will collect $480 more tax. We prefer not to make a partnership return. The department will not recognize a division or sharing of the entire net income of a partnership as an allowable method of determining the salaries of the partners, although in rare cases the salaries may exhaust or even exceed the net income of the partnership. (See Article 32 of Regulation No. 41.) Every cTomestic part^ership having a net income of $6,000 or more without deducting salaries or interest paid to partners must make a return of income on Form 1065. CONCERNS IN OPERATION ONLY PART OF TAXABLE YEAR. 25. A partnership was established and began operations August 1, 1917. The capital invested was $300,000 and the net income for the five remaining months of 1917 was $60,000. What is the tax? As the net incom« covers only five-twelfths of a year, the deduction and the invested capital must be brought to the same basis. Five -twelfths of the total deduction for a full year is $12,500. (The percentage deduction for a full yea,r 1352 would be $24,000 and the specific deduction would be $6,000, a total of 30,000. Five-twelfths of the last figure is $12,500.) Five-twelfths of the total invested capital is $125,000. Thus in this case the tax would be computed on the basis of an invested capital of $125,000, net income of $60,000, and a total deduction of $12,500. The tax would be $20,750. 26. A Corporation organized July 1, 1917, makes $2,400 in the last half of that year. Is it required to make return and pay excess-profits tax? Yes. A corporation engaged in business for only a part of the year must make return if its net income is. at the rate of $3,000 or more per annum. A similar rule applies to an in- dividual or partnership engaged in business for only part of the taxable year; a return must be made and the excess- profits tax paid if the net income for the taxable year is at the rate of $6,000 or more. (This answer does not apply in the case of a corporation or partnership whose first fiscal year ends in 1918 and which has secured permission to make its return on the basis of its fiscal year.) INVESTED CAPITAL. 87. Section 207 (clause 3) authorizes the inclusion in in- vested capital of "paid in or earned surplus and undivided profits used or employed in the business." Can a corporation or partnership have any surplus or undivided profits which for purposes of the excess-profits tax will not be deemed to be used or employed in the business? All the surplus and undivided profits of a corporation or partnership (exclusive of undivided profits earned during the year), will, unless invested in assets the income from which Is not subject to the excess-profits tax, be deemed to be used or employed in the business and may be included in the in- vested capital. (See Article 62 of Regulations No. 41.) 28. A corporation balances its books monthly, carrying profits into surplus account. Is the capital as of January lat increased for the purposes of the excess-profits tax by the addition of these monthly profits? No. The law specifically excludes undivided profits earned during the taxable year. The profits accumulated during the year, even though entered on the books as surplus before the close of the year, can not be counted as additions to the capi- tal for that year. (See Article 61 of Regulations No. 41.) 29. In computing invested capital for the purposes of the excess-profits tax, may a corporation take as the value of its capital stock the amount fixed by the department for the pur- poses of the capital-stock tax? No. Each return must be prepared in accordance with the provisions of the law under which it is made. 30. According to Section 207, bonds (other than obligations of the United States), the income from which is not subject to the excess-profits tax, can not be included in invested capi- tal. Section 200 states that "The term 'United States* means only the States, the Territories of Alaska and Hawaii and the District of Columbia." May State bonds be included in in- vested capital? No. The above defmition applies only in a geographical sense. The term "United States" in the parenthetical clause 1353 above is not used in a geographical sense. Hence the term "obligations of the United States" means only obligations of the Federal Government. 31. In 1901 a corporation was organized and took over the assets of a dozen going concerns, issuing therefor $25,000,000 of capital stock The assets consisted of various plant struc- tures, equipment, real estate, patents, and good will. At the time of the transaction all of these items were entered in a lump sum and no attempt was made to indicate the specific amounts of stock issued for the respective kinds of property. It is shown that at that time the tangible property was worth $10,000,000, the patents $2,000,000, and the good will not less than $7,000,000. How is the invested capital to be computed? In accordance with Article 59 of Regulations No. 41, it will be presumed that $12,000,000 of the stock was issued for the tangible property and the patents and that $13,000,000 was issued for good will. The tangible property will be taken at its value as of January 1, 1914, but not to exceed $10,000,000, the par value of the stock deemed to have been issued for it. The patents will be taken at their value at the time of ac- quisition, namely, $3,000,000. Although $13,000,000 of stock was issued for the good will, it can be taken at only $5,000,000, i. e., 20 per cent of the total stock outstanding on March 3, 1917. 32. A banking corporation began operations in 1902. In the course of 12 years, for reasons of conservatism, the bank charged off practically the entire value of its building, and sihce January 1, 1915, has been carrying it on its books at the nominal figure of $1. Can any of this value be restored for the purpose of computing invested capital? Yes. The building may be taken at cost, less a fair allow- ance for depreciation. However, any amounts which may have been allowed as a deduction for depreciation under the income- tax law can not be restored. 33. A farmer bought a piece of land December 1, 1913. He has put no new money in the business, but has spent all his income from the land for tile and ditching. The farm cost originally $4,000, and is now easily worth $10,000. In com- puting invested capital should the value as of January 1, 1914, be taken? No. The property will be valued at cost, less depreciation (on buildings, etc.), plus the amount of earnings from year to year invested in the permanent improvement of the prop- erty. 34. Article 18 of the Regulations says that when the de- duction is determined under Artcile 24 a "constructive" capi- tal will be used for applying the rates of taxation. It may be that in some cases it will be impossible to determine satis- factorily the invested capital for the pre-war period, but quite possible to determine the invested capital for the taxabl« year. In such cases the deduction will be determined under Article 24. Will the constructive capital described in Article 18 be used? No. The constructive capital is to be used only in cases where it is impossible to determine satisfactorily the invested capital for the taxable year. 1354 35. In 1900 a corporation was organzed and took over a mining property then valued at $1,000,000. For this property the corporation issued stock to the amount of $1,000,000. Ai a result of development, the discovery of new ore bodies^ etc., the property increased in value until in 1910 after an appraisal it was entered on the books at $10,000,000 and the surplus was increased accordingly. In 1917 another appraisal was had and the value of the property was then fixed at $15,000,000. The balance sheet of the corporation now shows capital stock of $1,000,000 and a surplus of $20,000,000, of which $14,000,000 is represented by the appreciation in value above described. May the appraised value of the property be taken as the basis for computing invested capital? No. The excess-profits tax law expressly places the com- putation of invested capital upon the basis of the cash and other property actually put into the business, plus the earned surplus and undivided profits, and not upon that of a present valuation or appraisal of its assets. Returns in which the invested capital includes surplus or undivided profits com- puted upon present values as determined by an appraisal can not be accepted. 36. In 1907 a corporation acquired a manufacturing plant valued at $500,000, issuing therefor $500,000 of capital stock. The books of the corporation on December 31, 1916^ showed a surplus of $1,000,000, accumulated through the earnings of the business. Most of this surplus was invested in increased plant equipment, etc. In December, 1917, the property was appraised (as of Jan. 1, 1917) by an appraisal company and the value fixed at $2,500,000, or $1,000,000 more than the values previously shown on the books. This increase was attributable mainly to increased value of land and in part to larger values placed by the appraisal company upon the machinery and equipment. May this appreciation of $1,000,000 be regarded as an earned surplus, and the value fixed by the appraisal company in December, 1917, be taken as a basis for computing invested capital for that year? No. The same rule applies here as in the case stated in question No. 35. For the purposes of the excess profits tax law appreciation in the value of property will not be regarded as earned surplus, and an appraisal of property upon current values will not be accepted as a basis for computing invested capital. 37. A proprietary medicine company has spent large sums in advertising and has thereby built up a good wilL May these sums be included as expenditures for a capital asset? If the money was spent from original capital the original capital is of course allowed. But if these advertising bills were paid from income and the amounts charged to general expense they can not be included as capital. Good will can be included only when bought and paid for specifically as such. RETURNS. 38. A corporation is engaged in the brokerage business, em- ploying only a nominal capital. According to Article 73 of the Regulations, it is taxable at the 8 per cent rate under Section 209 of the law. Its income tax return is made out on Form 1031. Must it also make out a return on Form 1103, which apparently relates only to corporations having an in- vested capital? 1355 Yes. Every corporation claiming to have only a nominal capital must file a return on Form 1103, however small its capitalization may be. 39. If a corporation claiming to have only a nominal capi- tal files a return on Form 1103, will this not be construed as an admission that it has invested capital and is taxable at the graduated rates under Section 201? No. This return is required for the sake of information, so as to enable the department to determine the justice of the claim. The two forms (1031 and 1103) should be filed to- gether and should be accompanied by a statement describing the nature of the business, the purposes for which the capital is employed, and any other facts tending to show that the corporation is of a kind properly taxable under Section 209, at the 8 per cent rate. 40. In the case of a corporation claiming to have only a nominal capital, on which form and under what schedule should the tax at the 8 per cent rate be computed? (a) In the case of a domestic corporation, take the net income as shown in item 6, Schedule I of Form 1103, com- pute 8 per cent on the amount thereof in excess of $3,000, and enter the result as item 12 on Form 1031. (b) In the case of a foreign corporation, if the net income shown in Item 6, Schedule I of Form 1103 is in excess of $3,000 the tax will be 8 per cent upon the whole amount and should be entered as Item 12 on Form 1031. (c) In either case it should be noted under Item 12 that the tax is computed at the 8 per cent rate. 41. If a corporation during 1917 made less than 7 per cent on its invested capital, is it required to file an excess-profits return? Every corporation having an income for the taxable year of $3,000 or over is required to file an excess-profits return, even though its total deduction may be in excess of its net income. 42. On Form 1065 (partnership -income return) it is stated on page 1, under "6. Excess Profits Tax," that "if the partner- ship reports any income from sources other than those in- cluded under A, page 3, it must make a return and compute the amount of tax (if any) on Form 1102." If a domestic part- nership rendering professional or personal services and report- ing its main income in block A also reports a small amount of interest from bank balances, etc., in block F, will it be re- quired to make a return on Form 1102? No. The income of a partnership or corporation (unlike that of an individual) must be taxed as a unit — all under the graduated rates or all at 8 per cent. (See Article 14 of Regu- lations No. 41.) If the partnership has a substantial amount of capital (however invested), return must be made on Form 1102 for purposes of information. (See answers 38 and 39 above.) But if the partnership has only a small capital and Is clearly taxable at the 8 per cent rate as to the income from its principal trade or business, any income which it derives from other sources will be taxed in the same manner and there will be no occasion for a return of invested capital. 43. In the case stated in question No. 42, how should the tax be computed? 1356 In every case the excess-projBts tax of a partnership is to bo computed upon the net income, as shown in block G, page 4, of Form 1065. In the case above stated this will consist of the sum of the totals reported under A and F. The tax will be 8 per cent upon the amount by which this sum exceeds $6,000. (The statement on page 4 of Form 1065 that the ex- cess-profits tax on a business with no invested capital, or only a nominal capital, will be "8 per cent of the amount by which the net total reported under A, page 3, exceeds $6,000, or in the case of a foreign partnership, 8 per cent of the entire net total reported under A" applies only in cases where the entire net income falls in block A.) 44. Will every partnership reporting income from business under block B, page 3 of Form 1065, be taxable at the gradu- ated rates under Section 201? Not necessarliy. Every partnership reporting income under block B must make a return on Form 1102. But if it is clear that its principal trade or business consists in rendering per- sonal service (income reported under block A) and is taxable at the 8 per cent rate, all of its income will be taxed at that rate even though a part of it may be derived from "invested capital." 45. Block C, on page 3 of Form 1065, provides space for entering profits from sale of real estate, stocks, bonds, and other property. If a partnership sustains a net loss from such transactions can it take account of such loss in computing its net income subject to the excess-profits tax? Yes. The loss should be entered in red ink or as a negative quantity in block C. 46. On the individual excess-profits tax return (Form 1101) there appears under schedule B a column for entering the "Cost" of assets acquired except "tangible property put into the business." Where should the value of tangible property put into the business be entered? In the same column (column 2, headed "Cost"). If the property was put in before January 1, 1914, enter the value as of that date; if put in on or before that date, enter the value as of the time when put in. In all such cases enter along with the description of the asset the date when it was paid in. 47. If an individual who keeps books reports his invested capital in schedule A on Form 1101, must he also fill out schedule B? Not necessarily. If invested capital is reported in schedule A, the return should be accompanied by a statement explaining adjustments. In many cases, however, it may be advisable to fill in the spaces provided in schedule B for the description of assets and their proper valuation. This may be useful in connection with the explanatory statement. 48. Item 7 in schedule A of Form 1101 (individual excess- profits tax return) calls for the excess of inadmissible assets over liabilities. Should an individual reporting his invested capital in schedule A specify the amount of liabilities and in- admissible assets respectively under items 23 to 27 of sched- ule B? Yes. This is the most convenient way of explaining item 7 of schedule A. 1357 49. How does a member of a partnership, in making his individual income-tax return, report his credit for his propor- tionate share of the excess-profits tax assessed against the partnership? Does he add that share to any excess-profits tax assessed against him as an individual and report this sum in block L on Form 1040? No. On Form 1065, page 4, the partnership takes credit for its excess-profits fax (block J) before arriving at the net in- come to be shared by the partners (block K). So the indi- vidual partner in reporting his total net income (Form 1040, block K) has already deducted his proportionate share of the partnership excess -profits tax and he may not again include that share as a part of his deduction under block L of Form 1040. He should enter in that space only the amount of ex- cess-profits tax, if any, assessed against his as an individual. 50. On page 2 of Form 1065 (partnership-income return), under the heading "Other expenses" is the following instruc- tion: "Do not deduct salary for any partner's services unless such salary is paid in accordance with a prior agreement prop- erly recorded on the books of the partnership." Does this in- struction supersede Article 32 of the Regulations? No. With respect to any period prior to March 1, 1918, a salary deduction for services actually rendered will be al- lowed regardless of whether a previous agreement had been made. 51. A corporation in which most of the stock is owned by its officers has in the past voted to its officers only nominal salaries as drawing accounts. In computing net income for purposes of the excess-profits tax may the corporation deduct as items of expense amounts which would constitute reason- able compensation for the services actually rendered by its officers? Yes, if a satisfactory explanation is given. For any period prior to March 1, 1918, reasonable salaries for services actually rendered may be deducted, even though the full amounts had not been formally voted as salaries by the corporation. March 14, 1918. EXCESS PROFITS TAX SERIES— Letter No. 9. The questions in Letters 1 to 8, inclusive, have been re- arranged according to their subject matter and published in the "'Excess Profits Tax Primer." This and subsequent letters will serve as supplements to the Primer. 52. An individual is in the habit of balancing his books twice a year, on June 30 and on December 31. In computing his invested capital for 1917, may he take the state- ments on his books for December 31, L916, June 30, 1917, and December 31, 1917, and average the three? No. He should ascertain his capital as of December 31, 1916, and as of December 31, 1917, and take the average of the two. However, he may, if he prefers, ascertain the invested capital once each month and compute his invested capital for the year by the monthly average method. 1358 53. During the past six years a manufacturer has carried a loan of $100,000 from his bank. This is used in purchas- ing raw materials. For practical purposes it is a part of his working capital. May he include it in his invested capital? No. It is borrowed money and is specifically excluded by the law. 54. A grocer in business as an individual pays taxes of $1,800 on his stock and store building and $800 on his (separate) residence. May he deduct all of these taxes in computing his net income for purposes of the excess profits tax? No. The taxes on his store and stock, being incident to the business, may be deducted; but the tax on his residence is not deductible for purposes of the excess profits tax. 55. May an individual working on a salary of $10,000 deduct taxes of $500 on his residence on the ground that the residence is necessary to his personal service business? No. 56. An individual receives a salary of $10,000. His excess profits tax is $320. Does he pay income tax on the full $10,000? No. In addition to his personal exemption he may deduct the $320 excess profits tax before computing the income sub- ject to income tax. 57. My invested capital is $50,000; my net income $40,000; my total deduction $10,000; so that my taxable income is $30,000. How do I apply the graduated rates? Should I use only the $30,000 in determining the amount of income subject to the various rates? No. Your total net income of $40,000 should be used for this purpose. The deduction comes out of the first bracket, but if it exceeds the amount of income in that bracket, then the rest of the deduction is allowed under the second and succeeding brackets until it is exhausted. In the above case the deduction exceeds 15 per cent of the capital (the amount of the net in- come in the first bracket, $7,500) and also absorbs all of the income in the second bracket ($3,500).' This leaves $2,500 to be taxed at the 35 per cent rate, $4,000 at the 45 per cent rate, and $23,500 at the 60 per cent rate. The total tax is $16,775. 58. In July, 1917, a patent medicine concern with a capital stock of $100,000 and owning assets, including good will, plainly worth $1,500,000, transferred its assets to a new corporation, receiving in payment therefor the total capital stock of the new company to the amount of $1,- 600,000. The stock of the old company was then can- celled, its stockholders receiving in exchange therefor the stock of the new corporation. In computing invested capital may the good will be included up to 20 per cent of the $1,500,000? No. In the case of a reorganization after March 3, 1917, where the control of the business remains in the same hands, nc asset transferred to the new company may be included at a greater value than would have been allowed to the old com- pany, unless the asset is actually purchased with cash or tan- gible property. In the above case, if the good will is allowed it may not be included at a value exceeding 20 per cent of the $100,000 capital stock of the old corporation, 1359 69. A manufacturing corporation owns 99 per cent of the stock of another corporation which has title to certain buildings, real estate, and other property used by the manufacturing corporation. May they make a consoli- dated return? Yea. An associated or subsidiary corporation which owns property employed in the business of another corporation will be deemed to be affiliated with the latter corporation and shall join with it in making a consolidated return for purposes of the excess profits tax if the controlling corporation owns 95 per cent or more of the stock of the subsidiary. March 15, 1918. EXCESS PROFITS TAX SERIES— Letter No. 10. 60. Two partners invested $4,000 each, with the understand- ing that the partners would pay them 8 per cent on this amount before distributing any other profits. Should the partnership deduct as expense the $640 so paid? No. It was a division of profits. However, if the notes of the partnership were issued for money actually loaned by the partners, the interest would be deductible but the amount of the loan could not be included in the invested capital. 61. A partnership conducts a merchandising business in which capital is employed. It also does a commission business entirely separate and apart from the merchan- dising business. May it report the merchandising busi- ness on Form 1102, computing the tax at the graduated rates, and report the commission business in Block A of Form 1065, computing the tax at the 8 per cent rate? No. All the trades or businesses of a partnership are treated as a single trade or business. All of its income will be clas- sified and taxed according to the nature of its principal trade or business. In the above case the partnership should report all of its income under the proper Blocks on Form 1065 and should also make a return on Form 1102. If the merchandising business is its principal business, then the tax will be com- puted at the graduated rates on Form 1102; if the commission business is its prmcipal business, the tax will be computed at the 8 per cent rate on Form 1065. In either case the tax should be computed upon the net income shown in Item G, page 4, of Form 1065. 62. A corporation has an authorized capital stock ot $500,- 000. $100,000 was issued for cash. In February, 1917, another $100,000 was issued for notes. The balance is unissued. May we count our paid up capital stock as $200,000? Bnforeible notes or other evidences of indebtedness, bearing a reasonable rate of interest, bona fide and lawfully received by a corporation in payment for its corporate stock may be considered as tangible property in computing invested capital. But if the interest on the notes is not paid within the taxable year or if the indebtedness evidenced thereby is not paid within a reasonable time, the obligations will be presumed to be colorable only and will be excluded in computing invested capital. If there is any agreement or understanding that such obligations are to be paid out of tlie earnings of the corpora- tion when distributed in the form of dividends or otherwise, 1360 then the obligations will not be regarded as tangible property paid in and the stock issued for them will not be regarded as paid up until the obligations are actually paid. 63. On December 15, 1916, a corporation declared a dividend to the amount of $100,000, payable March 25, 1917. Wai the $100,000 in question part of the invested capital on January 1, 1917? Yes. It may be treated as a part of the surplus until paid. If at the time of payment the 1917 profits were sufficient, the dividend will be deemed to have been paid out of the 1917 profits and the surplus carried forward from 1916 will not be reduced on account of this dividend. If, however, the 1917 earnings were not sufficient to pay the dividend, the surplus carried forward from 1916 will be reduced by the amount thereof required for the payment of the dividend. 64. A conservatively managed manufacturing plant has been charging depreciation on its machinery at the rate of 10 per cent a year. A considerable portion of its equip- ment has been entirely charged ofiE on its books, although the machinery is in use and at present prices is worth practically all it originally cost. May any of this de- preciation be restored to capital account? Under the conditions imposed by Article 64 of Regulations No. 41, a taxpayer may, in computing invested capital, restore to capital account any depreciation upon property still in use which was charged off prior to March 1, 1913, and is now shown to have been excessive, and also any depreciation charged ofT subsequent to March 1, 1913, which has been disallowed by the Bureau of Internal Revenue. 65. An individual balance sheet shows the following state- ment: Assets— Liabilities— Cash 125,000 Capital Account 1200,000 Merchandise 75,000 Accts. Payable ^ 100,000 Accts. Receivable 50,000 Securities 150,000 1300,000 1300,000 The securities consist entirely of municipal bonds and the stock of domestic corporations. They have always been carried as a business investment and are continu- ally used as collateral. What is the invested capital? $150,000 (assuming that due allowance has been made for adjustments in the capital account). The securities are inadmissible assets and exceed the liabilities (accounts pay- able) by $50,000. This amount should be entered as Item 7, Schedule A on Form 1101, and is to be subtracted from the adjusted capital account, $200,000. This leaves invested cap- ital of $150,000. March 19, 1918. EXCESS PROFITS TAX SERIES— Letter No. 11. NOTE. — Correction in Excess Profits Tax Primer.— On page 15 (item No. 1763, page 517, issue of March 19) of the Primer under Question No. 46, in the third line of the Answer, the word "before" should be "after," so that the second sentence will read as follows: "If the property was put in before January 1, 1914, enter the value as of that date; if put in on or after that date, enter the value as of the time when put in." 1361 66. A partnership engaged in the practice of law has a net income of $15,000. One partner draws a salary of $3,000 and the other $6,000, leaving $6,000 net for the partner- ship. The deduction for the partnership is $6,000, leav- no tax to be paid. The $6,000 profits, however, is paid to the partner drawing the $6,000 salary. Does he pay excess profits tax on the basis of an income of $12,000? No. He has a $6,000 deduction which covers his salary, and the $6,000 received in the form of partnership profits is not taxable to the individual partner under the Excess Profits Tax Law. In the above case, neither the partnership nor the individual partners will have any excess profits tax to pay. 67. A partnership has a capital of $60,000, including $10,000 invested in municipal bonds and the stock of domestic corporations. The dividends and interest received on the stock and bonds are figured as a part of the partner- ship profits for the year. May the $10,000 be included as a part of the invested capital? No. The income from this investment is not subject to the excess profits tax. The stocks and bonds in question are there- fore inadmissible assets and may not be included in the in- vested capital. 68. A corporation having a capital stock of $100,000 is en- gaged in the buying and selling of securities. During the year 1917 an average of $75,000 of its capital was invested in municipal bonds. Interest on the bonds amounted to $4,500; profits from the sale of the bonds amounted to $18,000. May any of the $75,000 invested in these bonds be included in invested capital? Yes. The total income from the bonds (interest plus trad- ing profits) was $22,500. The trading profits were four-fifths of this amount. Under Article 45 of Regulations No. 41, four- fifths of the amount ($75,000) invested in the bonds, namely, $60,000, may be included in the invested capital. 69. A corporation with a paid-up capital stock of $100,000 had accumulated a surplus of $20,000 on December 31, 1914. In 1915 the corporation suffered a loss through fire amounting to $50,000. Since then it has made up $10,000 of the loss. In computing invested capital must the capital be reduced by the amount of the loss which was in excess of the surplus and which has not yet been made up? In other words, will the invested capital now be reduced to $80,000? No. The invested capital will be $100,000. The loss must be taken into account only to the extent that it wiped out the surplus. The amount of the original cash investment need not be reduced for this purpose. However, no new surplus can be included in the invested capital until the full loss of $30,000 chargeable against the capital account has been made good. 70. When adjustments are made under Schedule B or C of Form 1103, must the corporation change its books ac- cordingly? It is not necessary that the books be changed, provided some permanent record of the adjustments be kept. 71. On December 31, 1917, a corporation set aside a reserve of $100,000 to pay the excess profits tax due in June, 1918, in case the current earnings should not be suffi- cient. May this $100,000 be included in the invested capital as of January 1, 1918? 1362 Yes. Although set aside as a reserve fund, it will be re- garded as a part of the siirplus. 72. In 1914 a corporation acquired a secret formula valued at that time at $500,000, issuing therefor $500,000 of capital stock. May the secret formula be included in invested capital at this figure? Not if this amount exceeds 20 per cent of the total stock outstanding March 3, 1917. Secret formulae or secret proc- esses are regarded as intangibles and are subject to the same limitations. March 22, 1918. EXCESS PROFITS TAX SERIES— Letter No. 13. 73. In the case of corporation A, the percentage deduction, carried out to two decimal places, is 8.69. In the case of corporation B, the percentage deduction is 8.23. Should A take 9 per cent and B 8 per cent, as the percentage to to be used in computing its deduction? In other words, should the decimal part be disregarded when less than half of 1 per cent and be increased to 1 per cent, when it amounts to one-half of 1 per cent or more? No. The exact percentage, including decimals, should be used. In figuring the percentage, carry out the result to as many decimal places as desired, but drop the remainder, if any, without increasing the final figure of the percentage. 74. If a taxpayer in making his excess profit tax return for 1917 wishes to be relieved from computing the pre-war data and accepts 7 per cent as his percentage deduction, will he be precluded in subsequent years from sub- mitting the pre-war data and taking whatever percent- age deduction such data would show him entitled to? No. 75. A corporation has a gross income in 1917 amounting to $4,000, but its net income was only $2,800. Will it be regarded as "having an income for the taxable year of $3,000 or over" and thus be required to file an excess profits return? No. Under existing regulations (Article 10, Regulations No. 41) an excess profits return is required only when the net income is $3,000 or over. 76. A domestic corporation has a net income of $8,000 and an invested capital of $100,000. It will be entitled to a deduction of at least $10,000, so that it will have no excess profits tax to pay. Must it file a return? Yes. Whenever the net income is $3,000 or over, the excess profits tax return will be required regardless of the amount of the deduction. 77. In October, 1917, a corporation invested $200,000 of its current earnings in Liberty bonds. May this amount be included in the invested capital for 1917? No. Although the Liberty bonds are "admissable" assets, their acquisition did not affect the invested capital for 1917. Profits of a taxable year, even though carried to surplus ac- count, cannot be included in invested capital for that year. 1363 78. An individual dealer in bonds began business in Jan- uary, 1917, with a capital of $20,000. He carried on an average through the year $700,000 municipal bonds and $100,000 corporate bonds. His average indebtedness foi the year was $600,000, on which he paid interest amount- ing to $30,000. His corporate bonds yielded interest to the amount of $5,000. The interest received from mu- nicipal bonds was $21,000; but the interest paid in in- debtedness incurred for carrying municipals amounted to $26,250, leaving a deficit of $5,250. The municipals were sold at a loss of $8,000; but the industrial bonds were sold at a sufficient figure to leave the dealer net trading profits for the year — after deducting all ex- penses other than interest— of $48,000. His taxable net income then consists of $53,000 (trading profits plus in- terest on corporate bonds) less deductible interest paid ($3,750), or $49,250; but since the non-deductible interest paid ($26,250) exceeds the tax free interest received ($21,000), his net income as computed on his own books is only $44,000, and he is in effect taxed on a $5,250 loss. May he include any part of the municipal bonds in his invested capital? No. No part of the municipal bonds may be treated as admissible assets under Article 45 inasmuch as a trade loss and not a gain was sustained from their sale. Moreover, in- debtedness upon which an interest deduction is denied cannot be included in invested capital under Article 44 when incurred for the purchase of inadmissible assets. However, under cir- cumstances such as those recited above application for assess- ment under Section 210 (Article 52) will be considered. 1364 Collection Districts A Complete List of Collection Districts, with the Names and Addresses of Collectors — (Numbers of districts represent the results of numerous amendments and consolidations. Unless otherwise mentioned, the entire State or Territory is included within the district designated.) District Collector Address Alabama John D. McNeel Birmingham (Includes State of Mississippi.) Alaska (see Washington). Arizona (see New Mexico). Arkansas Jack Walker Little Rock 1st California Justus S. Wardell San Francisco (Includes the counties of Alameda, Alpine, Amador, Butte, Calaveras, Colusa, Contra Costa, Del Norte, Eldorado, Fresno, Glenn, Humboldt, Inyo, Kings, Lake, Laasen, Madera, Marin, Mariposa, Mendocino, Merced, Modoc, Mono, Monterey, Napa, Nevada, Placer, Plumas, Sacramento, San Benito, San Francisco, San Joaquin, San Mateo, Santa Clara, Santa Cruz, Shasta, Sierra, Siskiyou, Solano, Sonoma, Stanislaus, Sutter, Tulare, Tehama, Trinity, Tuolumne, Yolo, Yuba; also, includes State of Nevada.) 6th California John P. Carter Los Angeles (Includes the counties of Imperial, Kern, Los Angeles, Orange, Riverside, San Bernardino, San Diego, San Luis Obispo, Santa Barbara and Ventura.) Colorado Mark A. Skinner Denver (Includes State of Wyoming.) Connecticut .. James J. Walsh Hartford (Includes State of Rhode Island.) Delaware (see Maryland). Florida James M. Cathcart Jacksonville Georgia Aaron 0. Blalock Atlanta Hawaii Howard Hathaway Honolulu Idaho (see Montana). Ist Hlinois Julius F. Smietanka Chicago (Including the counties of Boone, Carroll, Cook, Dekalb, Dupage, Grundy, Jo Daviess, Kane, Kankakee, Kendall, Lake, Lasalle, Lee, McHenry, Ogle, Stephenson, Whiteside Will and Winnebago.) 5th Hlinois Edward D. MeCabe Peoria (Including the counties of Bureau, Henderson, Henry, Knox, Marshall, Mercer, Peoria, Putnam, Rock Island, Stark and Warren. Date of present constitution of district, July 1, 1887.) 1365 District Collector Address 8th Illinois John L. Pickering Springfield (Including the counties of Adams, Bond, Brown, Callioun, Cass, Cliampalgn, Christian, Coles, Cumberland, Dewitt, Douglas, Edgar, Ford, Pulton, Greene, Hancock, Iroquois, Jersey, Livingston, Logan, McDonough, McLean, Macon, Macoupin, Mason, Menard, Montgomery, Morgan, Moultrie, Piatt, Pike, Sangamon, Schuyler, Scott, Shelby, Tazewell, Vermilion and Woodford.) 13th Illinois John M. Rapp East St. Louis (Including the counties of Alexander, Clark, Clay, Clin- ton, Crawford, Edwards, Effingham, Fayette, Franklin, Gallatin. Hamilton, Hardin, Jackson, Jasper, Jefferson, Johnson, Lawrence, Madison, Marion, Massac, Monroe, Perry, Pope, Pulaski, Randolph, Richland, St. Clair, Saline, Union, Wabash, Washington, Wayne, White and Will- iamson.) 6th Indiana Peter J. Kruyer Indianapolis (Including the counties of Adams, Allen, Bartholomew, Benton, Blackford, Brown, Cass, Dearborn, Decatur, De- kalb, Delaware, Elkhart, Fayette, Franklin, Fulton, Grant, Hamilton, Hancock, Hendricks, Henry, Howard, Hunting- ton, Jackson, Jasper, Jay, Jefferson, Jennings, Johnson, Kosciusko, Lagrange, Lake, Laporte, Lawrence, Madison, Marion, Marshall, Miami, Monroe, Morgan, Newton, Noble, Ohio, Porter, Pulaski, Randolph, Ripley, Rush, St. Joseph, Shelby, Starke, Steuben, Switzerland, Tipton, Union, Wa- bash, Wayne, Wells, White and Whitley.) 7th Indiana Isaac R. Strouse Terre Haute (Including the counties of Boone, Carroll, Clark, Clay, Clinton, Crawford, Davies, Dubois, Floyd, Fountain, Gib- son, Greene, Harrison, Knox, Martin, Montgomery, Orange, Owen, Parke, Perry, Pike, Posey, Putnam, Scott. Spencer, Sullivan, Tippecanoe, Vanderburg, Vermilion, Vigo, War- ren, Warrick and Washington.) 3d Iowa Louis Murphy Dubuque Kansas Wm. H. L. Pepperell Wichita 2d Kentucky Josh T. Griffith Owensboro (Including the counties of Allen, Ballard, Barren, Breck- enridge. But, Caldwell, Calloway, Carlisle, Christian, Clin- ton, Crittenden, Cumberland, Davies, Edmonson, Fulton, Graves, Grayson, Hancock, Hart, Henderson, Hickman, Hopkins, Livingston, Logan, Lyon, McCracken, McLean, Marshall, Metcalfe, Monroe, Muhlenberg, Ohio, Russell, Simpson, Todd, Trigg, Union, Warren and Webster.) 6th Kentucky ^ Thomas Scott Mayes Louisville (Including the city of Louisville and the counties of Adair, Bullitt, Casey, Green, Hardin, Henry, Jefferson, Larue, Marion, Meade, Nelson, Oldham, Owen, Shelby, Spencer, Taylor and Washington.) 6th Kentucky Charlton B. Thompson Covington (Including the counties of Boone, Bracken, Campbell, Carroll, Gallatin, Grant, Harrison, Kenton, Pendleton, Robertson and Trimble.) 7th Kentucky William P. D. Haly Lexington (Including the counties of Bath, Bourbon, Boyd, Carter, Clark, Elliott, Fayette, Fleming, Franklin, Greenup, John- son, Lawrence, Lewis, Martin, Mason, Menifee, Mont- gomery, Morgan, Nicholas, Powell, Rowan, Scott and Woodford.) 8th Kentucky John W. Hughes . Danville (Including the counties of Anderson, Bell, Boyle, Brea- thitt, Clay, Estill, Floyd, Garrard, Harlan, Jackson, Jessa- mine, Knott, Knox, Laurel, Lee, Leslie, Letcher, Lincoln, Madison, Magoffin, Mercer, McCreary, Owsley, Perry, Pike, Pulaski, Rockcastle, Wayne, Whitley and Wolfe.) Louisiana John Y. Fauntleroy New Orleans 1366 District Collector AddresB Maine (see New Hampshire). Maryland Joshua W. Miles Baltimore (Including the States of Maryland and Delaware, the District of Columbia, and the counties of Accomac and Northampton of the State of Virginia.) 3d Massachusetts John F. Malley Boston 1st Michigan James J. Brady Detroit (Including counties of Alcona, Alpena, Arenac, Bay, Branch, Calhoun, Cheboygan, Clare, Clinton, Crawford, Genesee, Gladwin, Gratiot, Hillsdale, Huron, Ingham, Iosco, Isabella, Jackson, Lapeer, Lenawee, Livingston, Macomb, Midland, Monroe, Montmorency, Oakland, Ogemaw, Oscoda, Otsego, Presque Isle, Roscommon, Saginaw, Sanilac, Shia- wassee, St. Clair, Tuscola, Washtenaw and Wayne.) 4th Michigan Emanuel J. Doyle Grand Rapids (Including counties of Alger, Allegan, Antrim, Baraga, Barry, Benzie, Berrien, Cass, Charlevoix, Chippewa, Delta, Dickinson, Eaton, Emmet, Gogebic, Grand Traverse, Hough- ton, Ionia, Iron, Kalamazoo, Kalkaska, Kent, Keweenaw, Lake, Leelanau, Luce, Mackinac, Manistee, Marquette, Mason, Mecosta, Menominee, Missaukee, Montcalm, Muske- gon, Newaygo, Oceana, Ontonagon, Osceola, Ottawa, St. Joseph, Schoolcraft, Van Buren and Wexford.) Minnesota Edward J. Lynch St. Paul Mississippi (see Alabama). 1st Missouri Geo. H. Moore St. Louis (Including the counties of Adair, Audrian, Bollinger, Boone, Butler, Callaway, Cape Girardeau, Carter, Clark, Crawford, Dent, Dunklin, Franklin, Gasconade, Howard, Iron, Jefferson, Knox, Lewis, Lincoln, Linn, Macon, Madi- son, Maries, Marion, Mississippi, Montgomery, Monroe, New Madrid, Oregon, Osage, Pemiscot, Perry, Phelps, Pike, Pulaski, Ralls. Randolph, Reynolds, Ripley, St. Charles, St. Francois, Ste. Genevieve, St. Louis, Schuyler, Scotland, Scott, Shannon, Shelby, Stoddard, Warren, Washington and Wayne.) 6th Missouri Edgar M. Harbor Kansas City (Including the counties of Andrew, Atchison, Barry, Barton, Bates, Benton, Buchanan, Caldwell, Camden, Carroll, Cass, Cedar, Chariton, Christian, Clay, Clinton, Cole, Cooper, Dade, Dallas, Daviess, Dekalb, Douglas, Gentry, Greene, Grundy, Harrison, Henry, Hickory, Holt, Howell, Jackson, Jasper, Johnson, Laclede, Lafayette, Lawrence, Livingston, McDonald, Mercer, Miller, Moniteau, Morgan, Newton, Nodaway, Ozark, Pettis, Platte, Polk, Putnam, Ray, St. Clair, Saline, Stone, Sullivan, Taney, Texas, Vernon, Webster, Worth and Wright.) Montana William C. Whaley Helena (Includes States of Idaho and Utah.) Nebraska Geo. L. Loomis Omaha Nevada (see 1st California). New Hampshire Seth W. Jones Portsmouth (Includes States of Maine and Vermont.) Ist New Jersey , Samuel Iredell Camden (Including the counties of Atlantic, Burlington, Camden, Cape May, Cumberland, Gloucester, Mercer, Monmouth, Ocean and Salem.) 6th New Jersey - Charles V. Duffy Newark (Including the counties of Bergen, Essex, Hudson, Hunterdon, Middlesex, Morris, Passaic, Somerset, Sussex, Union and Warren.) 1367 District Collector Address New Mexico Lewis T. Carpenter Phoenix, Ariz. (Includes State of Arizona.) 1st New York Bertram Gardner (Acting) Brooklyn (Including the counties of Kings, Nassau, Queens, Rich- mond and Suffolk.) 2d New York Wm. H. Edwards New York City (Including the first, second, third, fourth, fifth, sixth, eighth, ninth and fifteenth wards of New York City; that portion of the fourteenth ward lying west of the centre of Mott Street ; that portion of the sixteenth ward lying south ot the centre of West Twenty-fourth Street, and Governors Isiand). 3d New York Mark Eisner New York City (Including the seventh, tenth, eleventh, twelfth, thirtenth, seventeenth, eighteenth, nineteenth, twentieth, twenty-first and twenty-second wards of New York City ; that part of the fourteenth ward lying east of the centre of Mott Street ; that part of the sixteenth ward lying north of the centre of West Twenty-fourth Street, and Blackwells, Randalls and Wards Islands.) 14th New York Roscoe Irwin Albany (Including the counties of Albany, Clinton, Columbia, Dutchess, Essex, Fulton, Greene, Hamilton, Montgomery, Orange, Putnam, Rensselaer, Rockland, Saratoga, Schenec- tady, Schoharie, Sullivan, Ulster, Warren, Washington and Westchester, and the twenty-third and twenty-fourth wards of New York City.) 21st New York Neal Brewster Syracuse (Including the counties of Broome, Cayuga, Chenango, Cortland, Delaware, Franklin, Herkimer, Jefferson, Lewis, Madison, Oneida, Onondaga, Oswego, Otsego, St. Lawrence, Schuyler, Seneca, Tioga, Tompkins and Wayne.) 28th New York Vincent H. Riordan Buffalo (Including the counties of Allegany, Cattaraugus, Chau- tauqua, Chemung, Brie, Genesee, Livingston, Monroe, Niagara, Ontario, Orleans, Steuben, Wyoming and Yates.) 4th North Carolina Joshua W. Bailey Raleigh (Including the counties of Alamance, Beaufort, Bertie, Bladen, Brunswick, Camden, Carteret, Caswell, Chatham, Chowan, Columbus, Craven, Cumberland, Currituck, Dare, Duplin, Durham, Edgecombe, Franklin, Gates, Granville, Greene, Halifax, Harnett, Hertford, Hyde, Johnston, Jones, Lenoir, Martin, Montgomery, Moore, Nash, New Hanover, Northampton, Onslow, Orange, Pamlico, Pasquotank, Pender, Perquimans, Person, Pitt, Richmond, Robeson, Sampson, Scotland, Tyrrell, Vance, Wake, Warren, Wash- ington, Wayne and Wilson.) 6th North Carolina Alston D. Watts Statesville (Including the counties of Alexander, Allegany, Anson, Ashe, Buncombe, Burke, Cabarrus, Caldwell, Catawba, Cherokee, Clay, Cleveland, Davidson, Davie, Forsyth, Gas- ton, Graham, Guilford, Haywood, Henderson, Iredell, Jack- son, Lincoln, McDowell, Macon. Madison, Mecklenburg, Mitchell, Polk, Randolph, Rockingham, Rowan, Ruther- ford, Stanly, Stokes, Surry, Swain, Transylvania, Union, Watauga, Wilkes, Yadkin and Yancey.) No. & So. Dakota James Coffey Aberdeen, S. D. (Including States of North Dakota and South Dakota detached from District of Nebraska and constituted one district, to be known as the District of North and South 1st Ohio Andrew C. Gilligan Cincinnati (Including the counties of Brown, Butler, Clarke, Cler- mont, Clinton, Fayette, Greene, Hamilton, Highland, Miami, Montgomery, Preble and Warren.) 1368 District Collector Address 10th Ohio Frank B. Niles Toledo (Including the counties of Allen, Auglaize, Champaign, Crawford, Darke, Defiance, Erie, Fulton, Hancock, Hardin, Henry, Huron, Logan, Lucas, Mercer, Ottawa, Paulding, Putnam, Sandusky, Seneca, Shelby, Van Wert, Williams, Wood and Wyandot.) 11th Ohio Beriah E. Williams Columbus (Including the counties of Adams, Athens, Coshocton, Delaware, Fairfield, Franklin, Gallia, Guernsey, Hocking, Jackson, Knox, Lawrence, Licking, Madison, Marion, Meigs, Morgan, Muskingum, Noble, Perry, Pickaway, Pike, Ross, Scioto, Union, Vinton and Washington.) 18th Ohio - Harry H. Weiss Cleveland (Including the counties of Ashland, Ashtabula, Belmont, Carroll, Columbiana, Cuyahoga, Geauga, Harrison, Holmes, Jefferson, Lake, Lorain, Mahoning, Medina, Monroe, Port- age, Richland, Stark, Summit, Trumbull, Tuscarawas and Wayne.) Oklahoma Hubert L. Bolen Oklahoma City Oregon, Milton A. Miller Portland Ist Pennsylvania Ephraim Lederer Philadelphia (Including the counties of Berks, Bucks, Chester, Dela- ware, Lehigh, Montgomery, Philadelphia and Schuylkill.) 9th Pennsylvania Benjamin F. Davis Lancaster (Including the counties of Adams, Bedford, Blair, Cumberland, Dauphin, Franklin, Fulton, Huntingdon, Juniata, Lancaster, Lebanon, Mifflin, Perry, Snyder and York.) 12th Pennsylvania Fred C. Kirkendall Scranton (Including the counties of Bradford, Carbon, Centre, Clinton, Columbia, Lackawanna, Luzerne, Lycoming, Mon- roe, Montour, Northampton, Northumberland, Pike, Potter, Sullivan, Susquehanna, Tioga, Union, Wayne and Wy- oming.) 23d Pennsylvania C. Gregg Lewellyn Pittsburgh (Including the counties of Allegheny, Armstrong, Beaver, Butler, Cambria, Cameron, Clarion, Clearfield, Crawford, Elk, Erie, Fayette, Forest, Greene, Indiana, Jefferson, Lawrence, McKean, Mercer, Somerset, Venango, Warren, Washington and Westmoreland.) Rhode Island (see Connecticut). South Carolina Duncan C. Hayward Columbia South Dakota (see North and South Dakota). Tennessee Edward B. Craig Nashville 3d Texas Alexander S. Walker Austin Utah (see Montana). Vermont (see New Hampshire). 2d Virginia Richard C. L. Moncure Richmond (Including the counties of Amelia, Appomattox, Bruns- wick, Buckingham. Caroline, Charles City, Chesterfield, Cumberland, Dinwiddle, Elizabeth City, Essex, Fluvanna, Gloucester, Goochland, Greensville, Hanover, Henrico, Isle of Wight, James City, King and Queen, King George, King William, Lancaster, Louisa, Lunenburg, Mathews, Middle- sex, Nansemond, New Kent, Norfolk, Northumberland, Nottoway, Powhatan, Prince Edward, Prince George, Princess Anne, Richmond, Stafford, Southampton, Spott- Bylvania, Surry, Sussex, Warwick, Westmoreland and York.) 1369 District Collector Address 6th Virginia John M. Hart Roanoke (Including the counties of Albemarle, Alexandria, Alle- ghany, Amherst, Augusta, Bath, Bedford, Bland, Bote- tourt, Buchanan, Campbell, Carroll, Charlotte, Clarke, Craig, Culpeper, Dickenson, Fairfax, Fauquier, Floyd, Franklin, Frederick, Giles, Grayson, Greene, Halifax, Henry, Highland, Lee, Loudoun, Madison, Mecklenburg, Mont- gomery, Nelson, Orange, Page, Patrick, Pittsylvania, Prince William, Pulaski, Rappahannock, Roanoke, Rock- bridge, Rockingham, Russell, Scott, Shenandoah, Smyth, Tazewell, Warren, Washington, Wise and Wythe.) Virginia (for Accomac & Northampton counties, see Maryland) Washington David J. Williams Tacoma (Includes Territory of Alaska.) West Virginia Samuel A. Hays Farkersburg 1st Wisconsin Paul A. Hemmy Milwaukee (Including counties of Brown, Calumet, Dodge, Door, Florence, Fond du Lac, Forest, Green Lake, Kenosha, Kewaunee, Manitowoc, Marinette, Marquette, Milwaukee, Oconto, Outagamie, Ozaukee, Racine, Shawano, Sheboygan, Walworth, Washington, Waukesha, Waupaca, Waushara, Winnebago, and county of Langlade with exception of the eight townships of said county which were formerly in Lincoln County.) 2d Wisconsin Burt Williams Madison (Including the counties of Adams, Ashland, Barron, Bay- field, Buffalo, Burnett, Chippewa, Clark, Columbia, Craw- ford, Dane, Douglas, Dunn, Eau Claire, Grant, Greene, Iowa, Iron, Jackson, Jefferson, Juneau, La Crosse, Lafay- ette, Lincoln, Marathon, Monroe, Oneida, Pepin, Pierce, Polk, Portage, Price, Richland, Rock, Rusk, St. Croix, Sauk, Sawyer, Taylor, Trempealeau, Vernon, Vilas, Wash- burn, Wood, and the eight townships in the western part of Langlade County, which were formerly In Lincoln County.) Wyoming (gee Colorado). 1370 Additional Tax Schedules For Previous Tax Years The tables following show the amount of the additional taxes imposed under the Act of October 3, 1913, for the years 1913, 1914 and 1915, the Act of Sep- tember 8, 1916, and the Act of Septem- ber 8, 1916, as amended for the years 1916 and 1917, the latter two additional taxes being the same; the Act of Octo- ber 3, 1917 (War Income Tax) , for the year 1917. There is also given a combined table of the additional taxes due under the Act of September 8, 1916, as amended, and thei Act of October 3, 1917 (War Income Tax), for the year 1917. 1371 ADDITIONAL TAXES FOR THE YEARS 1913, 1914 AND 1915. The additional taxes imposed on net incomes of more than $20,000, according to the provisions of the Act of October 3, 1913, for the years 1913, 1914 and 1915, are as follows: ,; Annual Additional Tax Income of over ?20,000 and not over $50,000 1% Income of over 50,000 and not over 75,000 2% Income of over 75,000 and not over 100,000 3% Income of over 100,000 and not over 250,000 4% Income of over 250,000 and not over 500,000 5% Income of over 500,000 6% ADDITIONAL TAXES FOR THE YEARS 1916 AND 1917. The additional taxes imposed on net incomes of more than $20,000 for the year 1916, in accordance with the Act of September 8, 1916, and for the year 1917 under the Act of September 8, 1916, as amended, are as follows: Annual Additional Tax Income of over $20,000 and not over $40,000 1% Income of over 40,000 and not over 60,000 2% Income of over 60,000 and not over 80,000 3% Income of over 80,000 and not over 100,000 4% Income of over 100,000 and not over 150,000 5% Income of over 150,000 and not over 200,000 6% Income of over 200,000 and not over 250,000 7% Income of over 250,000 and not over 300,000 8% Income of over 300,000 and not over 500,000 9% Income of over 500,000 and not over 1,000,000 10% Income of over 1,000,000 and not over 1,500,000 11% Income of over 1,500,000 and not over 2,000,000 12% Income of over 2,000,000 13% 1373 ADDITIONAL TAXES FOR THE YEAR 1917. The additional taxes for the year 1917 imposed by the War Income Tax (Act of October 3, 1917) in excess of $5,000 are as follows : Annual Additional Tax Income of over $5,000 and not over $7,500 1% . Income of over 7,500 and not over 10,000 2% Income of over 10,000 and not over 12,500 3% Income of over 12,000 and not over 15,000 4% Income of over 15,000 and not over 20,000 5% Income of over 20,000 and not over 40,000 7% Income of over 40,000 and not over 60,000 10% Income fo over 60,000 and not over 80,000 14% Income of over 80,000 and not over 100,000 18% Income of over 100,000 and not over 150,000 22% Income of over 150,000 and not over 200,000 25% Income of over 200,000 and not over 250,000 30% Income of over 250,000 and not over 300,000 347o Income of over 300,000 and not over 500,000 37% Income of over 500,000 and not over 750,000 40% Income of over 750,000 and not over 1,000,000 45% Income of over 1,000,000 50% COMBINED ADDITIONAL TAXES FOR THE YEAR 1917. Combined tabulation of the additional taxes for the year 1917, computed under the Act of September 8, 1916, as amended, and the Act of October 3, 1917 (War Income Tax). Rate of Additional Tax Income of over $5,000 and not over $7,500 1% Income of over 7,500 and not over 10,000 2% Income of over 10,000 and not over 12,500 3% Income of over 12,500 and not over 15,000 4% Income of over 15,000 and not over 20,000 5% Income of over 20,000 and not over 40,000 8% Income of over 40,000 and not over 60,000 ^ 12% Income of over 60,000 and not over 80.000 - 17% Income of over 80,000 and not over 100,000 22% Income of over 100,000 and not over 150,000 27% Income of over 150,000 and not over 200,000 31% Income of over 200,000 and not over 250,000 37% Income of over 250,000 and not over 300,000 42% Income of over 300,000 and not over 500,000— 46% Income of over 500,000 and not over 750,000 50% Income of over 750,000 and not over 1,000,000 55% Income of over 1,000,000 and not over 1,500,000 61% Income of over 1,500,000 and not over 2,000,000 62% Income of over 2,000,000 63% 1374 status of Bonds "Under th© Federal IncomeTax! me lax"' 1919 Edition A recent ruling of the Department of Internal Revenue has completely changed the tax status of interest from corporation bonds. Under this ruling the Government cannot accept payment of taxes by a bond-issuing corporation in behalf of a bondholder where such bond does not contain a tax-free covenant. Yet here are some startling facts, based upon official information : (1) Not all corporations issuing bonds with a so-called tax-free covenant are observing the apparent terms of such covenant. (2) Many corporations issuing bonds without a tax-free covenant are reimbursing the holder for a tax of 2% or more. (3) Some corporations issuing bonds with a tax-free covenant are assuming more than the 2% tax which by law they are required to retain and pay in behalf of the bondholder. (4) Other corporations are paying coupons without deduction of the 2% tax only where a certificate of ownership is filed showing that the holder is not exempt from the tax. 1375 What the Bondholder Must Know It is no longer sufficient, therefore, that a bondholder know merely whether or not his bond contains a tax-free covenant. He must know also: (a) In the case of a tax-free bond, what amount of tax, if any, will be assumed by the issuing corporation. (b) In the case of bonds without a tax-free covenant, to what amount, if any, will the issuing corporation reimburse the bondholder. Without definite knowledge of these things there can be no certainty that the bondholder is not either overpaying his taxes or withholding payment legally due, and inno- cently making himself liable to Government action. How Your Tax is Made Up The reason why the bondholder must know these several points is that the annual income tax return of an individual is composed of two items: (a) The net income upon which taxes are to be paid directly to the Government. (b) The net income on which part of the tax is paid for him at the source of such income. From this second item springs a multitude of puzzling questions. According to law, the only part of the tax to be paid on behalf of the individual at its source is a tax of 2% on the interest from those corporation bonds which contain a so-called tax-free covenant. A tax-free covenant is an apparent agreement that the issuing corporation is to assume, in whole or in part, the specified tax against such interest. But to further comphcate the matter, this tax of 2% is only a part of the tax assessed against the interest from bonds and other corporate obligations. So each different issue of corporation bonds presents a new problem to the bondholder in the work of making out an income tax return. 1376 The reason for this is the difference between the apparent meaning of certain clauses, such as the so-called tax-free covenants, and the actual interpretation given them by the issuing corporation or its paying agents. This confusion results in underpaying or overpaying, neglecting to pay entirely, or paying unnecessarily the bondholders' income tax. In attempting to apply the provisions of the present Federal Income Tax Law, the bondholders simply cannot know, without reference to the issuing corporation or its paying agents, the policy adopted by the corporation to govern its payment of taxes on interest. The real intent of the issuer is often exactly opposite to the seeming intent as expressed in the bond. In many cases a radical change in policy was revealed through our work of gathering data, and many surprises are brought to light. There are hundreds of cases which show a complete reversal of interpretations since last year on the part of issuing corporations. It is this necessary information, not to be obtained from any other source, that is offered you in the "Status of Bonds Under the Federal Income Tax," 1919 Edition. It furnishes this data definitely, concisely and authoritatively on about 10,000 bonds, the issuing corporations or paying agents of which having contributed the information. (See specimen on last page.) The Safe Way for the Bondholder The 1919 Edition of "Status of Bonds Under the Federal Income Tax," containing the officially revised Hst of over 10,000 bonds, is as complete, accurate and up-to-date as it is possible for experienced statisticians to make it. No expense has been spared in compiling it. The in- formation it contains involves the querying of thousands of bond-issuing corporations and paying agents. In almost every case the data before reaching us was checked and signed by either an official of the issuing corporation or by the corporation's fiscal agent. 1377 In the few cases where it was impossible to obtain direct replies to inquiries, or where the information sought was not available, the best unofficial data was utilized. In each case of this kind the tax clause of the mortgage appears to corroborate the information given in the book. For individuals owning bonds, for investing corporations, for banks, for lawyers and for trustees and administrators of estates the ''Status of Bonds Under the Federal Income Tax" is a necessity to safe, accurate return of taxes. There is no substitute for it and no other collection of similar information. It is of the utmost usefulness not only in mak- ing an income tax return but also as a reference book in the making of new investments. This book gives information not available to you except through the arduous labor in assembling it and in making certain of its accuracy. It is offered you complete, correct, compact, and in a form for instant reference. Price List Many users of past editions of the book bought them in quantity for distribution among their customers or clients. A reduction in price is made for books furnished in quantity, and arrange- ments are made to print the name of the distributing com- pany in gold letters on the cover. Note the following price list: Single copies, $5.00 each 5 to 9 copies, 4.75 each 10 to 19 copies, 4.50 each 20 to 49 copies, 4.00 each Special prices will be quoted upon request on 100 copies and over. For stamping your name in gold on covers in lots of over 9 and less than 100 a charge of 35 cents per copy will be made. In lots of 100 or over there will be no extra charge for stamping. Standard Statistics Company, Inc. 47-49 West Street, New York City 1378 Specimen Page Showing how the information is compiled in the "Status of Bonds Under the Federal Income Tax." Note the contradictory information indicated by Does Bond WhatAmt. thp fi