Legal Opinion

Columbia, N. & L. R. Co. v. Commissioner

United States Tax Court

Decided January 31, 1950No. Docket No. 20634Published

Excess Profits Tax -- Credit Based Upon Invested Capital -- Borrowed Capital -- Indebtedness "Not Including Interest." -- Certificates of indebtedness issued by a corporation to its bondholders as consideration for their agreement to reduce the future rate of interest payable on its bonds do not evidence an "outstanding indebtedness (not including interest)" within the meaning of section 719 (a) (1), I. R. C., for the purpose of computing the corporation's excess profits…

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Excess Profits Tax -- Credit Based Upon Invested Capital -- Borrowed Capital -- Indebtedness "Not Including Interest." -- Certificates of indebtedness issued by a corporation to its bondholders as consideration for their agreement to reduce the future rate of interest payable on its bonds do not evidence an "outstanding indebtedness (not including interest)" within the meaning of section 719 (a) (1), I. R. C., for the purpose of computing the corporation's excess profits credit based upon invested capital.

1Opinion of the Court

Columbia, Newberry & Laurens Railroad Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Columbia, N. & L. R. Co. v. Commissioner

Docket No. 20634

United States Tax Court

14 T.C. 154; 1950 U.S. Tax Ct. LEXIS 286;

January 31, 1950, Promulgated

Decision will be entered for the respondent.

Excess Profits Tax -- Credit Based Upon Invested Capital -- Borrowed Capital -- Indebtedness "Not Including Interest." -- Certificates of indebtedness issued by a corporation to its bondholders as consideration for their agreement to reduce the future rate of interest payable on its bonds do not…

2Cases cited3 opinions

  1. Player Realty Co. v. CommissionerUnited States Tax Court · 1947
  2. Palm Beach Trust Co. v. CommissionerUnited States Tax Court · 1947
  3. Columbia, N. & L. R. Co. v. CommissionerUnited States Tax Court · 1950

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