Legal Opinion

Savings Feature of Relief Dep't v. Commissioner

United States Board of Tax Appeals

Decided March 29, 1935No. Docket Nos. 59486, 61156Published

1. The petitioner was created and operated to receive deposits of the savings of employees of the Railroad and to invest them in securities and in loans made exclusively to employees entitled to the benefits of the relief department of the Railroad on the security of first mortgages on real estate. The assets and funds were held and administered separately from those of the Railroad, and the entire earnings were paid to the depositors or held for their benefit.

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1. The petitioner was created and operated to receive deposits of the savings of employees of the Railroad and to invest them in securities and in loans made exclusively to employees entitled to the benefits of the relief department of the Railroad on the security of first mortgages on real estate. The assets and funds were held and administered separately from those of the Railroad, and the entire earnings were paid to the depositors or held for their benefit. The petitioner operated in several states. It had no capital stock represented by shares; was not chartered or organized under any…

1Opinion of the Court

THE SAVINGS FEATURE OF THE RELIEF DEPARTMENT OF THE BALTIMORE AND OHIO RAILROAD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Savings Feature of Relief Dep't v. Commissioner

Docket Nos. 59486, 61156.

United States Board of Tax Appeals

32 B.T.A. 295; 1935 BTA LEXIS 966;

March 29, 1935, Promulgated

1. The petitioner was created and operated to receive deposits of the savings of employees of the Railroad and to invest them in securities and in loans made exclusively to employees entitled to the benefits of the relief department of the Railroad on the security of first mortgages…

2Cases cited7 opinions

  1. Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
  2. Weer v. PageCourt of Appeals of Maryland · 1928
  3. State v. ScougalSouth Dakota Supreme Court · 1892
  4. A--C Inv. Asso. v. CommissionerUnited States Board of Tax Appeals · 1931
  5. Vaughan v. CommissionerUnited States Board of Tax Appeals · 1934

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