Missouri Pac. R.R. v. Commissioner
United States Board of Tax Appeals
1. Amounts set up on the taxpayer's books as representing the cost of transportation of men and materials used in connection with betterments and improvements are not under the facts presented deductible as operating expenses. 2. The taxpayer and American Refrigerator Transit Company, held to be affiliated.
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1. Amounts set up on the taxpayer's books as representing the cost of transportation of men and materials used in connection with betterments and improvements are not under the facts presented deductible as operating expenses. 2. The taxpayer and American Refrigerator Transit Company, held to be affiliated. American Refrigerator Transit Co.,14 B.T.A. 616, followed. 3. An amount paid by the taxpayer in 1920 to the Association of Railway Executivesheld to be deductible as an ordinary and necessary expense. 4. Where a railway company issued bonds at a discount which was at the date of issue…
1Opinion of the Court
*286OPINION.
Phillips:
The petition in this proceeding, as amended, raises 32 issues, each of which was numbered. The answer raised an issue which has been numbered 33. So far as seemed possible the facts have been set out under each numbered issue, but in several instances the same facts affect two or more issues. In such cases the facts are included under the earlier number and not repeated. We discuss the issues in the order in which they are numbered, except that all issues arising out of the Federal control settlement are grouped.
Under issue No. 3 the petitioner claims that the Commissioner…
2Cases cited5 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Marr v. United StatesSupreme Court of the United States · 1925
3Cited by23 opinions
- Southern Natural Gas Company v. The United StatesUnited States Court of Claims · 1969
- W. M. Ritter Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Louisville & N. R. Co. v. CommissionerUnited States Tax Court · 1976
- Clark Thread Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Michigan Cent. R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
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