New York, C. & S. L. R. Co. v. Commissioner
United States Board of Tax Appeals
1. The sale in 1920 by the L.E. & W.R.R. Co. of its shares of the N.O. Ry. Co., its leasehold interest in that corporation's properties, and its claims against that corporation for advances, resulted in no deductible loss, as there was no statutory basis for such loss, and the claim was worthless prior to the taxable year. 2. The deduction of the L.E. & W. in 1920 for maintenance held properly reduced by an amount accrued from the Director General as part of the settlement…
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1. The sale in 1920 by the L.E. & W.R.R. Co. of its shares of the N.O. Ry. Co., its leasehold interest in that corporation's properties, and its claims against that corporation for advances, resulted in no deductible loss, as there was no statutory basis for such loss, and the claim was worthless prior to the taxable year. 2. The deduction of the L.E. & W. in 1920 for maintenance held properly reduced by an amount accrued from the Director General as part of the settlement of mutual claims arising from Federal control and attributed to undermaintenance. 3. Various claims for deductible losses…
1Opinion of the Court
*1276OPINION.
Steenhagen :
The respondent sent to the petitioner two notices of the same deficiency in the 1920 income tax of the former Lake Erie & Western Railroad Company, one treating the petitioner as the taxpayer and the other as a transferee of the taxpayer. From each notice, the petitioner, as the, successor by consolidation, instituted a separate proceeding. It admits its liability for whatever deficiency may be held to be correct as to the Lake Erie. Both proceedings *1277were consolidated, since they were in their substantive issues identical. It is suggested either that the transferee…
2Cases cited3 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Burnet v. HoustonSupreme Court of the United States · 1931
3Cited by11 opinions
- Baltimore & O. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- General Mfg. Corp. v. CommissionerUnited States Tax Court · 1965
- Pittsburgh & Lake Erie R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
- Ann Arbor R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
- Illinois C. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
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