Baltimore & O. R. Co. v. Commissioner
United States Board of Tax Appeals
1. Pursuant to the terms of a contract providing for the relocation of certain tracks without expense to it, a subsidiary of the petitioner received a sum representing the capitalized increased cost to the recipient of operating its trains and maintaining its tracks due to the increase in length of and increase in curvature in the new tracks over the replaced assets.
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1. Pursuant to the terms of a contract providing for the relocation of certain tracks without expense to it, a subsidiary of the petitioner received a sum representing the capitalized increased cost to the recipient of operating its trains and maintaining its tracks due to the increase in length of and increase in curvature in the new tracks over the replaced assets. Held, that the amount represents prepayment of ordinary and necessary business expenses and constitutes taxable income. 2. The petitioner received amounts for the cost of constructing side and spur tracks under contracts…
1Opinion of the Court
THE BALTIMORE AND OHIO RAILROAD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Baltimore & O. R. Co. v. Commissioner
Docket No. 37239.
United States Board of Tax Appeals
30 B.T.A. 194; 1934 BTA LEXIS 1357;
March 28, 1934, Promulgated
1. Pursuant to the terms of a contract providing for the relocation of certain tracks without expense to it, a subsidiary of the petitioner received a sum representing the capitalized increased cost to the recipient of operating its trains and maintaining its tracks due to the increase in length of and increase in curvature in the new tracks over…
2Cases cited42 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- United States v. United Shoe Machinery Co. of New JerseySupreme Court of the United States · 1917
- Lovejoy v. CommissionerUnited States Board of Tax Appeals · 1930
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