Legal Opinion

Green Bay & W. R. Co. v. Commissioner

United States Tax Court

Decided February 28, 1944No. Docket No. 111726Published

Green Bay & Western Railroad Co. had outstanding during the taxable years shares of common stock and certain class A and class B debentures. The debentures had no fixed date of maturity and provided for no fixed rate of annual return. They provided that the holders thereof should "in lieu of interest thereon, participate in the distribution of annual net income" in the manner set out in the debentures.

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Green Bay & Western Railroad Co. had outstanding during the taxable years shares of common stock and certain class A and class B debentures. The debentures had no fixed date of maturity and provided for no fixed rate of annual return. They provided that the holders thereof should "in lieu of interest thereon, participate in the distribution of annual net income" in the manner set out in the debentures. Any disbursements in pursuance of such provisions had to be declared by the board of directors of the corporation in the same manner that dividends on the common stock were declared. It was…

1Opinion of the Court

Green Bay & Western Railroad Company and The Ahnapee & Western Railway Company, Petitioners, v. Commissioner of Internal Revenue, Respondent

Green Bay & W. R. Co. v. Commissioner

Docket No. 111726

United States Tax Court

3 T.C. 372; 1944 U.S. Tax Ct. LEXIS 181;

February 28, 1944, Promulgated

Decision will be entered for the respondent.

Green Bay & Western Railroad Co. had outstanding during the taxable years shares of common stock and certain class A and class B debentures. The debentures had no fixed date of maturity and provided for no fixed rate of annual return. They provided that the holders…

2Cases cited1 opinion

  1. Green Bay & W. R. Co. v. CommissionerUnited States Tax Court · 1944

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