Bridgeport Hydraulic Co. v. Commissioner
United States Tax Court
1. Income Deduction -- Retirement of Bonds -- Expense or Cost of New Issue. -- The unamortized cost of issuance and the cost of retirement are deductible when bonds are unconditionally called and the debt is paid in cash even though in a separate transaction a new issue is sold at about the same time to the holders of the old bonds. 2. Amortization -- Retirement of Bonds Through Exchange of New Issue. -- The unamortized cost of issuance and the cost of retirement of old…
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1. Income Deduction -- Retirement of Bonds -- Expense or Cost of New Issue. -- The unamortized cost of issuance and the cost of retirement are deductible when bonds are unconditionally called and the debt is paid in cash even though in a separate transaction a new issue is sold at about the same time to the holders of the old bonds. 2. Amortization -- Retirement of Bonds Through Exchange of New Issue. -- The unamortized cost of issuance and the cost of retirement of old bonds are added to the cost of a new issue exchanged for the old. South Carolina Continental Telephone Co., 10 T. C. 164,…
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency of $186,293.21 in the excess profits tax of the petitioner for 1945. The issues for decision are (1) whether the unamortized discount upon issued and the premium paid upon retirement in 1945 of the petitioner’s series H, I, and J bonds are deductible in full in 1945 or should be amortized over the life of the new series K bonds issued in 1945; (2) whether the cost of a refunding in 1939 which was allowed to be deducted in that year should be included in the amount which should either be deducted in 1945 or amortized over the…
2Cases cited7 opinions
- Great Western Power Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Commissioner of Int. Rev. v. Coastwise Transp. Corp.Court of Appeals for the First Circuit · 1934
- Commissioner v. Coastwise Transp. Corp.Court of Appeals for the First Circuit · 1932
- Helvering v. California Oregon Power Co.Court of Appeals for the D.C. Circuit · 1935
- Congress Square Hotel Co. v. CommissionerUnited States Tax Court · 1945
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- 12701 Shaker Boulevard Co. v. CommissionerUnited States Tax Court · 1961
- Bridgeport Hydraulic Company v. Frank W. Kraemer and John J. Fitzpatrick, Collectors of Internal Revenue for the District of ConnecticutCourt of Appeals for the Second Circuit · 1955
- Husky Oil Co. v. CommissionerUnited States Tax Court · 1984
- Bridgeport Hydraulic Co. v. CommissionerUnited States Tax Court · 1954
- Commissioner of Internal Revenue v. Bridgeport Hydraulic CompanyCourt of Appeals for the Second Circuit · 1955
2 more not listed; retrieve them via the Exa API.