Legal Opinion

New Orleans Land Co. v. Commissioner

United States Board of Tax Appeals

Decided September 14, 1933No. Docket No. 48003PublishedCited by 2 opinions

Held, that in the circumstances herein the city of New Orleans owed no money to petitioner at any time material to the issue in controversy and that no payment made to petitioner was interest on an obligation of such city.

1Opinion of the Court

OPINION.

Lansdon:

The respondent has determined a deficiency in income tax for the year 1927, in the amount of $39,528.90. The only issue is whether certain amounts received by the petitioner in the taxable year represented interest on obligations of the city of New Orleans and so were exempt from Federal income tax under the provisions of section 213 of the Revenue Act of 1926.1 The facts are not in dispute and are stipulated as follows:

That the New Orleans Land Company was the owner of a certain tract of land located in the city of New Orleans, and that on November 24, 1925, the New Orleans…

2Cases cited4 opinions

  1. Kansas City S. Ry. v. CommissionerUnited States Board of Tax Appeals · 1929
  2. Cleveland v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Marine Transport Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Klein v. CommissionerUnited States Board of Tax Appeals · 1932

3Cited by2 opinions

  1. Du Pont v. DeputyDistrict Court, D. Delaware · 1938
  2. New Orleans Land Co. v. CommissionerUnited States Board of Tax Appeals · 1933

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