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
Southern Pacific Transportation Company, Transferee, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Southern Pacific Transp. Co. v. Commissioner
Docket Nos. 7501-72, 7502-72, 8646-72, 8647-72, 8648-72
United States Tax Court
90 T.C. 771; 1988 U.S. Tax Ct. LEXIS 48; 90 T.C. No. 51;
April 21, 1988; As amended July 1, 1988 April 21, 1988, Filed
Decisions will be entered under Rule 155.
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…
Also in this document: Dissent.
2Cases cited21 opinions
- Cammarano v. United StatesSupreme Court of the United States · 1959
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Textile Mills Securities Corp. v. CommissionerSupreme Court of the United States · 1941
- Gay Law Students Ass'n v. Pacific Telephone & Telegraph Co.California Supreme Court · 1979
- People v. RicciardiCalifornia Supreme Court · 1943
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