Southern Pacific Transp. Co. v. Commissioner
United States Tax Court
P, engaged in the business of furnishing railroad transportation, deducted expenditures made in connection with its support of, or opposition to, ballot propositions pending before the State electorate of Arizona and the State and certain local electorates of California. P had a direct interest in the outcome of all the ballot propositions which it supported or opposed. Held, P is not entitled to a deduction under sec. 162(e), I.R.C. 1954, for these expenses.
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P, engaged in the business of furnishing railroad transportation, deducted expenditures made in connection with its support of, or opposition to, ballot propositions pending before the State electorate of Arizona and the State and certain local electorates of California. P had a direct interest in the outcome of all the ballot propositions which it supported or opposed. Held, P is not entitled to a deduction under sec. 162(e), I.R.C. 1954, for these expenses. P spent approximately $ 4.9 million in connection with the construction of 47 public highway overpasses above its tracks and roadbeds.…
1Opinion of the Court
JACOBS, Judge:
Notices of income tax deficiencies and transferee liabilities for these consolidated cases concern the years 1962 through 1968.2 The deficiencies, as determined by respondent, are as follows:
Year Amount3
1962 . $14,087,392
1963 . 10,718,321
1964. 11,446,017
1965 . 8,827,875
1966 . 8,972,806
1967 . 10,590,947
1968. 21,499,083
Petitioners claim overassessments and overpayments of tax for these years in excess of $100 million.
The parties have settled, or have informed the Court that they will be able to settle, all but 5 of the more than 150 issues in this case. One of the unsettled issues…
2Cases cited9 opinions
- Cammarano v. United StatesSupreme Court of the United States · 1959
- Textile Mills Securities Corp. v. CommissionerSupreme Court of the United States · 1941
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
- Denver & Rio Grande Western Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1960
- Denver & R. G. W. R. Co. v. CommissionerUnited States Tax Court · 1959
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Cloud v. CommissionerUnited States Tax Court · 1991
- New England Electric System v. United StatesUnited States Court of Federal Claims · 1993
- Cloud v. CommissionerUnited States Tax Court · 1991
- Geary v. CommissionerUnited States Tax Court · 1999
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1988