Legal Opinion

Richmond, F. & P. R. Co. v. Commissioner

United States Tax Court

Decided May 14, 1974No. Docket No. 1024-70Published

1. During the year 1929, petitioner had outstanding the same issues of 6-percent and 7-percent "guaranteed stock" as are involved in the instant case. In that year, petitioner paid "guaranteed dividends" at the specified rate to the holders of its guaranteed stock and also paid its guaranteed stockholders an "excess dividend" to equalize with the dividends paid its common stockholders.

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1. During the year 1929, petitioner had outstanding the same issues of 6-percent and 7-percent "guaranteed stock" as are involved in the instant case. In that year, petitioner paid "guaranteed dividends" at the specified rate to the holders of its guaranteed stock and also paid its guaranteed stockholders an "excess dividend" to equalize with the dividends paid its common stockholders. Petitioner claimed all of such payments as deductible interest on its 1929 tax return which respondent disallowed in full. The Board of Tax Appeals, in Richmond, Fredericksburg & Potomac Railroad Co., 33 B.T.A.…

1Opinion of the Court

Richmond, Fredericksburg and Potomac Railroad Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Richmond, F. & P. R. Co. v. Commissioner

Docket No. 1024-70

United States Tax Court

62 T.C. 174; 1974 U.S. Tax Ct. LEXIS 113; 62 T.C. No. 20;

May 14, 1974, Filed

The parties are directed to move with respect to further proceedings in this case, or otherwise act, on or before June 3, 1974.

1. During the year 1929, petitioner had outstanding the same issues of 6-percent and 7-percent "guaranteed stock" as are involved in the instant case. In that year, petitioner paid "guaranteed…

Also in this document: Dissent · Withey; Dissent · Drennen; Dissent · Wiles.

2Cases cited24 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. Bankers Mortgage Company v. United StatesCourt of Appeals for the Fifth Circuit · 1970
  4. The Evergreens v. NunanCourt of Appeals for the Second Circuit · 1944
  5. United States v. Consolidated Edison Co. of NYSupreme Court of the United States · 1961

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