Legal Opinion

Union P. R. Co. v. Commissioner

United States Board of Tax Appeals

Decided April 16, 1935No. Docket Nos. 51530, 70183, 70219Published

1. In a consolidated return of affiliated railroad corporations, the cost of intercompany transportation of material used in capital construction must be eliminated from operating expense deduction.

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1. In a consolidated return of affiliated railroad corporations, the cost of intercompany transportation of material used in capital construction must be eliminated from operating expense deduction. Such cost figure, upon the evidence, determined to be 7 mills per ton mile. 2. Section 203, Revenue Act of 1926, is designed, as a general rule, to recognize gain or loss upon the exchange of property and to provide specific exceptions. 3. Exchange of property originally acquired for a proposed new railroad line the construction of which was later abandoned, whereupon the property was held for…

1Opinion of the Court

UNION PACIFIC RAILROAD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Union P. R. Co. v. Commissioner

Docket Nos. 51530, 70183, 70219.

United States Board of Tax Appeals

32 B.T.A. 383; 1935 BTA LEXIS 956;

April 16, 1935, Promulgated

1. In a consolidated return of affiliated railroad corporations, the cost of intercompany transportation of material used in capital construction must be eliminated from operating expense deduction. Such cost figure, upon the evidence, determined to be 7 mills per ton mile.

2. Section 203, Revenue Act of 1926, is designed, as a general rule, to…

2Cases cited29 opinions

  1. Helvering v. TaylorSupreme Court of the United States · 1935
  2. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  3. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  4. United States v. LudeySupreme Court of the United States · 1927
  5. Woolford Realty Co. v. RoseSupreme Court of the United States · 1932

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