St. Louis, Rocky Mountain & Pacific Co. v. Commissioner
United States Tax Court
Premium paid by petitioner to its bondholders upon the repurchase of its outstanding first mortgage bonds and interest paid to a trustee under bond indenture are deductions which must be allocated between income from mining operations and income from other activities in computing the 50 per cent of net income limitation on petitioner's coal depletion deduction under section 114 (b) (4), I. R. C. 1939.
1Opinion of the Court
OPINION.
Withey, Judge:
The respondent determined deficiencies in petitioner’s income tax for the indicated years as follows:
Tear Deficiency
1951_1_$5, 571. 96
1952_ 19,276.85
The issues presented by the pleadings and not disposed of by stipulation are the correctness of the respondent’s action (1) in determining that premiums paid by petitioner to its bondholders for the repurchase of its first mortgage bonds during 1951 and 1952 and the amount paid to the trustee under bond indenture during 1952 are deductions which must be allocated between income from mining operations and other income in…
2Cases cited3 opinions
- B. F. Goodrich Co. v. CommissionerUnited States Tax Court · 1943
- Guanacevi Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
- Sheridan-Wyoming Coal Co. v. HelveringCourt of Appeals for the D.C. Circuit · 1941
3Cited by5 opinions
- Wisconsin Memorial Park Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- Island Creek Coal Co. v. CommissionerUnited States Tax Court · 1964
- Island Creek Coal Co. v. CommissionerUnited States Tax Court · 1964
- St. Louis, Rocky Mountain & Pacific Co. v. CommissionerUnited States Tax Court · 1957
- Wisconsin Memorial Park Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958