Legal Opinion
St. Louis-San Francisco Railway Company v. The United States
United States Court of Claims
Decided July 14, 1971No. 289-65, 303-66PublishedCited by 11 opinions
1Opinion of the Court
ON PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT RESPECTING THE DEBT DISCOUNT ISSUE AND DEFENDANT’S CROSS MOTION FOR PARTIAL SUMMARY JUDGMENT
COWEN, Chief Judge.
These cases come before the court on cross-motions for partial summary judgment. Plaintiff is seeking tax refunds for the years of 1953 through 1961. At issue in this proceeding are the years 1955 through 1961. The main question before us now is the troublesome one of the existence and measurement of debt discount when a corporation exchanges new debt obligations for its outstanding debt obligations and its outstanding stock. Since two…
2Cases cited12 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- United States v. Felt & Tarrant Manufacturing Co.Supreme Court of the United States · 1931
- Union Pacific Railroad Company v. The United StatesUnited States Court of Claims · 1968
- American Smelting & Refining Co. v. United StatesCourt of Appeals for the Third Circuit · 1942
- Commissioner of Internal Revenue v. Carl L. Danielson and Pauline S. Danielson, Commissioner Ofinternal Revenue v. Helen P. Sherman, Commissioner Ofinternal Revenue v. Estate of Jacob F. Schaffner, Deceased, Elizabeth Schaffner and Erwin Marsch, Executors, and Elizabeth Schaffner, Commissionerof Internal Revenue v. Hugh E. McLennan and Katherine McLennanCourt of Appeals for the Third Circuit · 1967
7 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- United States v. St. Louis-San Francisco Railway Company, a Missouri Railroad CorporationCourt of Appeals for the Eighth Circuit · 1976
- Dakan v. United StatesUnited States Court of Claims · 1974
- GULF, MOBILE AND OHIO RAILROAD CO. v. United StatesDistrict Court, S.D. Alabama · 1972
- Claussen's, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
6 more not listed; retrieve them via the Exa API.