Legal Opinion

Monon Railroad v. Commissioner

United States Tax Court

Decided November 25, 1970No. Docket No. 5589-65Published

The petitioner, a publicly owned corporation, issued 50-year 6-percent income debentures in exchange for most of the outstanding stock of one class. Interest on the debentures was accrued and paid for a period of 15 months prior to their issuance. Held, the debentures are instruments of indebtedness on which interest is deductible when accrued, including the interest attributed to the 15-month period prior to issuance.

1Opinion of the Court

Monon Railroad (formerly Chicago, Indianapolis and Louisville Railway Company), Petitioner v. Commissioner of Internal Revenue, Respondent

Monon Railroad v. Commissioner

Docket No. 5589-65

United States Tax Court

55 T.C. 345; 1970 U.S. Tax Ct. LEXIS 26;

November 25, 1970, Filed

Decision will be entered under Rule 50.

The petitioner, a publicly owned corporation, issued 50-year 6-percent income debentures in exchange for most of the outstanding stock of one class. Interest on the debentures was accrued and paid for a period of 15 months prior to their issuance. Held, the debentures are instruments of…

2Cases cited43 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  4. Commissioner v. TowerSupreme Court of the United States · 1946
  5. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932

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