Pittsburgh & Lake Erie R.R. v. Commissioner
United States Board of Tax Appeals
1. Interest allowed by the Director General of Railroads on the cost of additions and betterments made during the period of Federal control held to be income during the period rather than in a later year when final settlement was made. 2. Back mail pay allowed to the petitioner pursuant to an order of the Interstate Commerce Commissionheld to constitute taxable income in the year when received. International-Great Northern R.R. Co.,24 B.T.A. 726, followed.
1Opinion of the Court
*261OPINION.
Smith:
On brief the respondent admits that the first issue is similar to that decided by the Board in the case of Texas & Pacific Ry. Co., 9 B.T.A. 365, which has been followed consistently in numerous decisions, wherein it was held that the allowance for interest on completed additions and betterments did not constitute income in the year of final settlement with the Director General of Railroads but was income during the period of Federal control. The respondent submits that under the decision mentioned and those following it, net taxable income for the year 1920 as shown in the…
2Cases cited7 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- Texas & Pac. Ry. v. CommissionerUnited States Board of Tax Appeals · 1927
- Union Pac. R.R. v. CommissionerUnited States Board of Tax Appeals · 1932
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3Cited by4 opinions
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