United Gas Improv. Co. v. Commissioner
United States Board of Tax Appeals
Held, the so-called "bonus" exacted from corporations by the State of Pennsylvania for the privilege of increasing authorized capital stock is not a tax, and does not constitute an allowable deduction in computing taxable net income under the provisions of section 234(a)(3) of the Revenue Act of 1926.
1Opinion of the Court
*1383OPINION.
Trammell :
The question raised in these proceedings is whether or not the payments made by the petitioner to the State of Pennsylvania on account of increases of its capital stock during the taxable years, under the circumstances indicated in the stipulated facts, constitute “taxes” within the purview of section 234 (a) (3) of the Revenue Act of 1926, which provides that in computing the net income of a corporation there shall be allowed as deductions, among other things, “ taxes paid or accrued within the taxable year,” with exceptions not important here.
The petitioner deducted the…
2Cases cited6 opinions
- Loan Assn. v. TopekaSupreme Court of the United States · 1875
- New Jersey v. AndersonSupreme Court of the United States · 1906
- Lane County v. OregonSupreme Court of the United States · 1869
- Choctaw, Oklahoma & Gulf Railroad v. HarrisonSupreme Court of the United States · 1914
- Pennsylvania v. York Silk Mfg. Co.Court of Appeals for the Third Circuit · 1911
1 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
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- United Gas Improv. Co. v. CommissionerUnited States Board of Tax Appeals · 1932