Columbus & G. R. Co. v. Commissioner
United States Tax Court
Petitioner acquired railroad properties at public auction in 1923 subject to a mortgage securing $ 5,660,000 in bonds due January 1, 1922, issued by Georgia Pacific Railway Co., a former owner of the properties, in 1882. The mortgage also covered other railroad properties of Georgia Pacific acquired by Southern Railway Co. at a public auction in 1894, subject to the mortgage.
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Petitioner acquired railroad properties at public auction in 1923 subject to a mortgage securing $ 5,660,000 in bonds due January 1, 1922, issued by Georgia Pacific Railway Co., a former owner of the properties, in 1882. The mortgage also covered other railroad properties of Georgia Pacific acquired by Southern Railway Co. at a public auction in 1894, subject to the mortgage. Pursuant to its charter and its own first mortgage, Southern issued its own first mortgage bonds in 1921 in an amount equal to the outstanding Georgia Pacific bonds, the proceeds from which were used by the trustee to…
1Opinion of the Court
DkbNNEN, Judge:
Respondent determined the following deficiencies in income tax and in additions thereto under section 298 (b)1 for the taxable years 1951,1952, and 1953:
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The parties have filed a stipulation in which it is agreed, inter alia, that petitioner is not liable for the additions to tax under section 293(b) for the 3 years involved herein but that an addition to tax under section 293(a) is due from petitioner for the taxable year 1953, and respondent has filed amendment to answer making claim for the addition to tax under section 293(a). All other issues raised by the…
2Cases cited8 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- Albany Car Wheel Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- Blackstone Theatre Co. v. CommissionerUnited States Tax Court · 1949
- Edwards v. CommissionerUnited States Tax Court · 1952
3 more not listed; retrieve them via the Exa API.
3Cited by49 opinions
- Estate of Baron v. CommissionerUnited States Tax Court · 1984
- Mayerson v. CommissionerUnited States Tax Court · 1966
- Waddell v. CommissionerUnited States Tax Court · 1986
- Jackson v. CommissionerUnited States Tax Court · 1986
- Saviano v. CommissionerUnited States Tax Court · 1983
44 more not listed; retrieve them via the Exa API.