Legal Opinion

Milwaukee & Suburban Transport Corp. v. Commissioner

United States Tax Court

Decided November 18, 1959No. Docket Nos. 61395, 72017UnpublishedCited by 1 opinion

1. Petitioner paid certain amounts as dividends on its preferred stock, issued in connection with its purchase of the mass public passenger transportation system in the City of Milwaukee from a corporation which was compelled to divest itself of the same in order to comply with the provisions of the Public Utility Holding Company Act of 1935. Held: Said dividends are not deductible as "interest on indebtedness," within the meaning of section 23(b) of the 1939 Code and…

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1. Petitioner paid certain amounts as dividends on its preferred stock, issued in connection with its purchase of the mass public passenger transportation system in the City of Milwaukee from a corporation which was compelled to divest itself of the same in order to comply with the provisions of the Public Utility Holding Company Act of 1935. Held: Said dividends are not deductible as "interest on indebtedness," within the meaning of section 23(b) of the 1939 Code and section 163(a) of the 1954 Code, inasmuch as the preferred stock represented an equity investment and not a debt. 2.…

1Opinion of the Court

Milwaukee & Suburban Transport Corporation v. Commissioner.

Milwaukee & Suburban Transport Corp. v. Commissioner

Docket Nos. 61395, 72017.

United States Tax Court

T.C. Memo 1959-216; 1959 Tax Ct. Memo LEXIS 31; 18 T.C.M. (CCH) 1039; T.C.M. (RIA) 59216;

November 18, 1959

1. Petitioner paid certain amounts as dividends on its preferred stock, issued in connection with its purchase of the mass public passenger transportation system in the City of Milwaukee from a corporation which was compelled to divest itself of the same in order to comply with the provisions of the Public Utility Holding Company…

2Cases cited17 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Lucas v. American Code Co.Supreme Court of the United States · 1930
  3. Brown v. HelveringSupreme Court of the United States · 1934
  4. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  5. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944

12 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Supermarkets General Corp. v. United StatesDistrict Court, D. New Jersey · 1982

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