Helvering v. Richmond, F. & P. R. Co.
Court of Appeals for the Fourth Circuit
1Opinion of the Court
PARKER, Circuit Judge.
This is a petition by the Commissioner of Internal Revenue to • review a decision of the Board of Tax Appeals relating to the 1929 income tax of the Richmond, Fredericksburg & Potomac Railroad Company. The question involved is the right of the taxpayer to a deduction on account of guaranteed “dividends” paid during the tax year on certain guaranteed stock, which constituted a first lien on taxpayer’s assets both with respect to the principal amount of the stock and the guaranteed dividends. On $481,000 of this preferred stock, dividends had been guaranteed at the rate of…
2Cases cited13 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Logan v. DavisSupreme Court of the United States · 1914
- Warren v. KingSupreme Court of the United States · 1883
- Commissioner of Internal Revenue v. OPP Holding Corp.Court of Appeals for the Second Circuit · 1935
- Commissioner of Internal Revenue v. Proctor ShopCourt of Appeals for the Ninth Circuit · 1936
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3Cited by54 opinions
- Jackson Mobilphone Co. v. Tennessee Public Service Comm.Court of Appeals of Tennessee · 1993
- Commissioner of Int. Rev. v. Meridian & Thirteenth R. Co.Court of Appeals for the Seventh Circuit · 1942
- Gooding Amusement Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1956
- United States v. Title Guarantee & Trust Co.Court of Appeals for the Sixth Circuit · 1943
- United States v. South Georgia Ry. Co.Court of Appeals for the Fifth Circuit · 1939
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