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p tributions to petitioner were provided by citizens of the respective communities who neither sought nor could have anticipated any direct service or recompense whatever, their only expectation being that such contributions might prove advantageous to the community at large. Under these circumstances the transfers manifested a definite purpose to enlarge the working capital of the company.13 The assets transferred by the community groups are likewise contributions to petitioner’s capital for the pur­pose of computing its invested capital credit.1 Cf. I. R. C. § 728. Precisely the same interpretation has been placed by the relevant Treasury* Regulations upon the term “ contribution to capital appearing in 5 718 (a ) as upon the like expression in the ( income tax provi­sions. 11 That the excess profits tax provision character­izes capital contributions as being “invested” and “paid in” does not indicate, as the Commissioner urges, that the concept of capital is the constricted one of legal capital or capital originating with persons haying a 13 C o m m issio n er v. A rm d e l-B ro o k s C oncrete C o rp ., 152 F. 2d 225 (C. A. 4th Ctr. 19451, relied upon by the court, only the issue whether the full cost of a concrete mibxeilnowg, pliannvto,l vtehde cnoenasrtb ryu ctsiuopnp hoefr wohfi cah rwaaws mfaitnearnicaedl- uisn edp aritn bmiyx ipnagy mceonntcrse tfe,r owma sa depreciable to the taxpayer; there was no “contribution to capital” imsesnuet,s tihne tohnalty cqausees twieorn eb emiandge o nine coofn csoisdte rbaatsiiosn. ofH osweervviecre, rtehned epraedy.­The construction of the concrete plant directly benefited the supplier of raw materials'- by insuring the use of its sole product by the tax­payer ‘ the supplier was also served through a business- atnixation ewxictlhu stihvee mpaarreknett inofg tahrer awnhgoelmleyn to wwnheidc ht asxapvaeyde rt hien stuhpep hfeorr mt hoef eaxn­pense of a sales organization. See A rttn d el-B ro o k * C on crete C o rp . v. Cotm« gjoexea rB.roenwesrt. e1r2,9 T Fh.e 2Fde d7efri2a l1 CE.x cAe.s s4 tPrho fCiitrs. T1a9x4,2) 1.1 0-1 111 194 i f. » Tress. Reg. 109, §30.718-1; Treas Reg. 112, §35718-1 The Commissioner agrees that the term “contribution to capital” is used with the same meaning in §§ 113 (a) (8) IBs and < 18 (a). BROWN SHOE CO. | COMMISSIONER. 9