Alleghany Corp. v. Commissioner
United States Tax Court
During 1929 and 1930, petitioner acquired more than half of the common stock of the MissouriPacific Railroad Company. In 1933, all of the property of Missouri Pacific was placed under the jurisdiction of the Federal courts and the Interstate Commerce Commission for reorganization under section 77 of the Bankruptcy Act. The original reorganization plans of the Commission provided for a reorganization of Missouri Pacific with no value being allotted to the old common stock.
Read the full summary
During 1929 and 1930, petitioner acquired more than half of the common stock of the MissouriPacific Railroad Company. In 1933, all of the property of Missouri Pacific was placed under the jurisdiction of the Federal courts and the Interstate Commerce Commission for reorganization under section 77 of the Bankruptcy Act. The original reorganization plans of the Commission provided for a reorganization of Missouri Pacific with no value being allotted to the old common stock. During the taxable years 1948 through 1952, petitioner expended $ 541,113.64 in opposing the original reorganization plans…
1Opinion of the Court
OPINION.
Arundell, Judge:
Respondent has determined deficiencies and has made claim for increased deficiencies in the income tax of petitioner as follows:
[[Image here]]
The only issue remaining is whether certain amounts deducted by petitioner in its corporation income tax returns for the years 1948 through 1952 under the heading, “Protection of investment in stock of Mo. Pac. E. E. Co. (in reorganization under Bankruptcy Act)” are deductible as ordinary and necessary business expenses under section 23 (a) (1) (A) of the Internal Revenue Code of 1939,1 as petitioner contends, or should be…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Hochschild v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1947
8 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Anchor Coupling Company, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1970
- Snow v. CommissionerUnited States Tax Court · 1958
- Industrial Aggregate Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Roussel v. CommissionerUnited States Tax Court · 1961
- Hoover Co. v. CommissionerUnited States Tax Court · 1979
37 more not listed; retrieve them via the Exa API.