Richmond, F. & P. R. Co. v. Commissioner
United States Tax Court
1. During the year 1929, petitioner had outstanding the same issues of 6-percent and 7-percent "guaranteed stock" as are involved in the instant case. In that year, petitioner paid "guaranteed dividends" at the specified rate to the holders of its guaranteed stock and also paid its guaranteed stockholders an "excess dividend" to equalize with the dividends paid its common stockholders.
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1. During the year 1929, petitioner had outstanding the same issues of 6-percent and 7-percent "guaranteed stock" as are involved in the instant case. In that year, petitioner paid "guaranteed dividends" at the specified rate to the holders of its guaranteed stock and also paid its guaranteed stockholders an "excess dividend" to equalize with the dividends paid its common stockholders. Petitioner claimed all of such payments as deductible interest on its 1929 tax return which respondent disallowed in full. The Board of Tax Appeals, in Richmond, Fredericksburg & Potomac Railroad Co., 33 B.T.A.…
1Opinion of the Court
TaNNenwald, Judge:
Respondent determined deficiencies in Federal income taxes against the petitioner for the taxable years 1962, 1963, and 1964 in the following amounts:
Year Deficiency
1962 -$35,398
1963 - 633
1964 - 70,897
Also for determination are the overpayments in income tax cla by the petitioner as follows:
Year Overpayment
1962 -.-$185,975
1963 -1- 34,785
1964 -1-•_ 163,289
On December 17,1971, the Revenue Act of 1971 was passed by the Congress amending the Internal Revenue Code. The Act provided, in part, an additional investment credit for railroads and bad retroactive effect. Based upon the…
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