Legal Opinion

Baltimore & Ohio R.R. v. Commissioner

United States Board of Tax Appeals

Decided November 21, 1933No. Docket No. 53702Published

1. Reductions from the recited figure above par, at which a corporation offers shares of stock, equal to 6 percent on the par value of the share between date of offer and date of issuance, do not constitute interest paid by the corporation. 2. Amounts paid to bankers and the costs of printing and listing, all of which are incidental to the issuance of common shares, are not deductible by the issuing corporation as ordinary and necessary expenses. 3. Value on March 1, 1913,…

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1. Reductions from the recited figure above par, at which a corporation offers shares of stock, equal to 6 percent on the par value of the share between date of offer and date of issuance, do not constitute interest paid by the corporation. 2. Amounts paid to bankers and the costs of printing and listing, all of which are incidental to the issuance of common shares, are not deductible by the issuing corporation as ordinary and necessary expenses. 3. Value on March 1, 1913, of shore lands on Staten Island, New York, determined. 4. The amount of an award, and interest thereon, upon the…

1Opinion of the Court

THE BALTIMORE AND OHIO RAILROAD COMPANY AND AFFILIATED CORPORATIONS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Baltimore & Ohio R.R. v. Commissioner

Docket No. 53702.

United States Board of Tax Appeals

29 B.T.A. 368; 1933 BTA LEXIS 950;

November 21, 1933, Promulgated

1. Reductions from the recited figure above par, at which a corporation offers shares of stock, equal to 6 percent on the par value of the share between date of offer and date of issuance, do not constitute interest paid by the corporation.

2. Amounts paid to bankers and the costs of printing and listing, all of which…

2Cases cited9 opinions

  1. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  2. Anderson & Co. v. CommissionerUnited States Board of Tax Appeals · 1927
  3. Bliss v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Daniel Bros. Co. v. CommissionerUnited States Board of Tax Appeals · 1927
  5. Marsh & Marsh, Inc. v. CommissionerUnited States Board of Tax Appeals · 1926

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