Paris & M. P. R. Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner is not entitled to credit for amount of adjusted net income under section 26(c)(1), Revenue Act of 1936, even though, under an existing capital deficit, it was prohibited by a Federal law from distributing its profits earned in taxable year as dividends.
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1. Petitioner is not entitled to credit for amount of adjusted net income under section 26(c)(1), Revenue Act of 1936, even though, under an existing capital deficit, it was prohibited by a Federal law from distributing its profits earned in taxable year as dividends. Crane-Johnson Co. v. Helvering,311 U.S. 54, followed. 2. Petitioner is entitled, under section 26(c)(2), to a credit of $14,000, the amount of current earnings set aside as a sinking fund payment, that amount being less than it was required to pay into the sinking fund, cf. Brockway Glass Co.,43 B.T.A. 267, and the payment…
1Opinion of the Court
PARIS & MT. PLEASANT RAILROAD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. 1
Paris & M. P. R. Co. v. Commissioner
Docket No. 103578.
United States Board of Tax Appeals
47 B.T.A. 439; 1942 BTA LEXIS 695;
August 4, 1942, Promulgated
1. Petitioner is not entitled to credit for amount of adjusted net income under section 26(c)(1), Revenue Act of 1936, even though, under an existing capital deficit, it was prohibited by a Federal law from distributing its profits earned in taxable year as dividends. Crane-Johnson Co. v. Helvering,311 U.S. 54, followed.
2. Petitioner is entitled,…
2Cases cited8 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Crane-Johnson Co. v. HelveringSupreme Court of the United States · 1940
- Michigan Silica Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Crane Johnson Co. v. CommissionerUnited States Board of Tax Appeals · 1938
- Brockway Glass Co. v. CommissionerUnited States Board of Tax Appeals · 1941
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