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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.’4 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 § 718 (a) as upon the like expression in the income tax provi­sions.’ 3 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 having a . . . -----r '?'Commissioner v. Arundcl-Hrooks Concrete Corp., 152 V. 2d 225 (C. A. dth Cir. 1945), relied upon by the court below, involved only the issue whether the full cost of a concrete mixing plant, the construction of which was financed in part by payments from a nearby supplier of a raw material used in mixing concrete, was depreciable to the taxpayer; there was no “ contribution to capital” issue, the only question being one of cost basis. However, the pay­ments in that case were made in consideration of service rendered. 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 affiliation with the parent of the wholly owned taxpayer in the form of an exclusive marketing arrangement which saved the supplier the ex­pense of a sales organization. See Arundcl-Rrooks (,'oncrete ('orp. v. Commissioner, 129 K. 2d 762 (C A. 4th Cir. 1942). H See Brewster, The Federal Excess Profits Tax, 110-111 (1941). 10 Treas. Reg, 109, §.'10.718-1; Treas. Reg. 112, §35.718-1. The Commissioner agrees that the term “contribution to capital" is used with the same meaning in §§ 113 (a) (8) (B) and 718 (a). BROWN SHOE CO. v. COMMISSIONER. 9