Great N. R. Co. v. Commissioner
United States Board of Tax Appeals
1. Losses sustained in certain taxable years through the liquidation of 100 percent owned subsidiaries determined and allowed. 2. Amounts charged to capital as interest on advances for construction of branch lines of railroad are not deductible from petitioner's income in the year in which such advances were written off as losses. 3. Taxes paid by petitioner in certain taxable years are not deductible in year of payment where under the law such taxes were accruable in a…
Read the full summary
1. Losses sustained in certain taxable years through the liquidation of 100 percent owned subsidiaries determined and allowed. 2. Amounts charged to capital as interest on advances for construction of branch lines of railroad are not deductible from petitioner's income in the year in which such advances were written off as losses. 3. Taxes paid by petitioner in certain taxable years are not deductible in year of payment where under the law such taxes were accruable in a prior year. 4. Railroad equipment used in constructing capital additions to petitioner's property was used in its trade or…
1Opinion of the Court
OPINION.
Lansdon:
The respondent has determined deficiencies for the years 1926, 1927, 1928, 1929, and 1930 in the respective amounts of $149,075.23, $50,144.95, $39,447.45, $84,559.78, and $27,520.98. Several of the allegations of error pleaded by the petitioner have been settled by stipulation or abandonment. The issues remaining for consideration will be stated in connection with the numbered findings of fact and the discussion and decision of each of the submitted questions. The several proceedings have been consolidated for hear*692ing and report. The parties have filed a stipulation, which we…
2Cases cited15 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- United States v. MitchellSupreme Court of the United States · 1926
- Newton v. Consolidated Gas Co. of NYSupreme Court of the United States · 1922
- Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
- Great Northern Railway Co. v. CommissionerUnited States Board of Tax Appeals · 1927
10 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Southern Natural Gas Company v. The United StatesUnited States Court of Claims · 1969
- Brooks v. CommissionerUnited States Tax Court · 1968
- Idaho Power Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1973
- Estate of Broadhead v. CommissionerUnited States Tax Court · 1966
- Producers Chemical Co. v. CommissionerUnited States Tax Court · 1968
4 more not listed; retrieve them via the Exa API.