New York Cent. R. Co. v. Commissioner of Internal Rev.

SWAN, Circuit Judge.

The first question presented by the taxpayer’s petition is whether the discount on bonds sold by predecessor corporations, which were consolidated to form the petitioner, can be amortized over the life of the bonds and a proportionate part thereof be deducted in each of the taxable years in question. The taxpayer made its income returns upon the accrual basis. Had the petitioner itself issued the bonds, there could be no doubt of its right-to take a deduction of amortized bond discount in its income tax returns. Old Mission Portland Cement Co. v. Helvering, 293 U. S. 289,…