Legal Opinion

Michigan Cent. R.R. v. Commissioner

United States Board of Tax Appeals

Decided June 20, 1933No. Docket Nos. 19930, 19932, 34437, 62040Published

1. In 1917 the New York Central Railroad Co. paid to a wholly owned subsidiary coal corporation $309,244.64 to enable that corporation to carry certain unused coal lands as an investment.

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1. In 1917 the New York Central Railroad Co. paid to a wholly owned subsidiary coal corporation $309,244.64 to enable that corporation to carry certain unused coal lands as an investment. Held, the payment is not deductible as an ordinary and necessary expense. 2. An amount paid to the State of Illinois pursuant to state statute upon the issuance of petitioner's bonds, held deductible as taxes paid. 3. Where bonds were issued at a discount by corporations, predecessors of this taxpayer, held, that the petitioner is not entitled to deductions for the amortization of such discount. 4. The…

1Opinion of the Court

THE MICHIGAN CENTRAL RAILROAD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

THE NEW YORK CENTRAL RAILROAD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Michigan Cent. R.R. v. Commissioner

Docket Nos. 19930, 19932, 34437, 62040.

United States Board of Tax Appeals

28 B.T.A. 437; 1933 BTA LEXIS 1124;

June 20, 1933, Promulgated

1. In 1917 the New York Central Railroad Co. paid to a wholly owned subsidiary coal corporation $309,244.64 to enable that corporation to carry certain unused coal lands as an investment. Held, the payment is not deductible as an…

2Cases cited26 opinions

  1. Burnet v. LoganSupreme Court of the United States · 1931
  2. Weiss v. WeinerSupreme Court of the United States · 1929
  3. Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
  4. Holeproof Hosiery Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  5. Emerson Electric Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1926

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