Western Union Tel. Co. v. Commissioner
United States Board of Tax Appeals
1. The case of Gold & Stock Telegraph Co.,26 B.T.A. 914, followed on the question of income to the taxpayer. 2. The petitioner held liable as transferee. The taxpayer corporations many years ago parted with all of their property under a long term lease to the petitioner, which lease provided for a certain rental and provided further than this rental should be paid directly to the stockholders of the taxpayer.
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1. The case of Gold & Stock Telegraph Co.,26 B.T.A. 914, followed on the question of income to the taxpayer. 2. The petitioner held liable as transferee. The taxpayer corporations many years ago parted with all of their property under a long term lease to the petitioner, which lease provided for a certain rental and provided further than this rental should be paid directly to the stockholders of the taxpayer. The petitioner had been a stockholder of the taxpayer at least during the taxable year and thereafter. During those years the petitioner distributed a portion of the rent to those…
1Opinion of the Court
*271OPINION.
Murdock:
In the case of Gold & Stock Telegraph Co., 26 B. T. A. 914, we held that the entire rental for the years 1920 and 1921, provided for in the agreements which Western Union Telegraph Company had with Gold & Stock Telegraph Company and Pacific and Atlantic Telegraph Company of the United States, was income to the lessors. In the present proceedings similar questions are raised in regard to rental under these two leases for the year 1926. On this point we adhere to our prior decision and the cases therein mentioned, without further discussion.
There is no contention in this case…
2Cases cited27 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Louisville & Nashville Railroad v. MottleySupreme Court of the United States · 1911
- Knox v. LeeSupreme Court of the United States · 1871
- Hollins v. Brierfield Coal & Iron Co.Supreme Court of the United States · 1893
- Scovill v. ThayerSupreme Court of the United States · 1882
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3Cited by1 opinion
- Western Union Tel. Co. v. CommissionerUnited States Board of Tax Appeals · 1932