Guantanamo & W. R. Co. v. Commissioner
United States Tax Court
Petitioner, a Maine corporation, transacted all its business in Cuba. In 1928, it executed in New York City a 30-year $ 3,000,000 bond issue which remained outstanding throughout the taxable years here involved. The bonds bore interest at 6 per cent, payable semi-annually on January 1 and July 1 in New York City. Petitioner adopted a fiscal accounting period ending June 30 and was on the accrual basis. In 1934, Cuba decreed a moratorium on debts.
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Petitioner, a Maine corporation, transacted all its business in Cuba. In 1928, it executed in New York City a 30-year $ 3,000,000 bond issue which remained outstanding throughout the taxable years here involved. The bonds bore interest at 6 per cent, payable semi-annually on January 1 and July 1 in New York City. Petitioner adopted a fiscal accounting period ending June 30 and was on the accrual basis. In 1934, Cuba decreed a moratorium on debts. The maturity date of all debts was fixed at June 30, 1970, and the rate of interest that could be demanded was fixed at 1 per cent on debts…
1Opinion of the Court
Arundell, Judge:
The respondent determined deficiencies in income tax for the taxable years ended June 30, 1949, June 30, 1950, and June 30,1951, in the respective amounts of $35,891.27, $32,354.72, and $44,932.56.
The issues remaining for our decision are:
1. Whether the respondent erred in disallowing deductions for interest expense under the provisions of section 23(b) of the Internal Revenue Code of 1939 of $120,000, $90,000, and $90,000 for the taxable years ended June 30,1949,1950, and 1951, respectively.
2. Whether the respondent erred in disallowing deductions for depreciation of bridges…
2Cases cited16 opinions
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- Baltimore Transfer Co. v. CommissionerUnited States Tax Court · 1947
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3Cited by2 opinions
- United States v. Waterman Steamship CorporationCourt of Appeals for the Fifth Circuit · 1964
- Guantanamo & W. R. Co. v. CommissionerUnited States Tax Court · 1959