Richmond, Fredericksburg & Potomac R.R. v. Commissioner
United States Board of Tax Appeals
Petitioner corporation, duly authorized, issued "guaranteed stock" secured by mortgage and having priority over general creditors. Held, that the fixed periodic payments, although denominated "dividends", were in reality interest, deductible as such from income.
1Opinion of the Court
opinion.
Yan Fossan:
This proceeding was brought to redetermine a deficiency in the income tax of the petitioner for the year 1929 in the sum of $11,220.59.
Two questions are at issue:(1) The deductibility as interest of certain payments on “ guaranteed stock ” secured by first mortgage.(2) The proper amount of retirement loss on certain roadway and structures.
The petitioner was incorporated by an act of the General Assembly of Virginia on February 5, 1834.
During the year 1929, 7 percent guaranteed stock of the petitioner of the par value of $481,000 and 6 percent guaranteed stock of the par…
2Cited by14 opinions
- Richmond, F. & P. R. Co. v. CommissionerUnited States Tax Court · 1974
- Gilboy v. CommissionerUnited States Tax Court · 1978
- Bakers' Mut. Co-operative Asso. v. CommissionerUnited States Board of Tax Appeals · 1939
- Benjamin Franklin Life Assurance Co. v. CommissionerUnited States Board of Tax Appeals · 1942
- Davidson Bldg. Co. v. CommissionerUnited States Tax Court · 1961
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