Legal Opinion
The Montana Power Company v. United States
Court of Appeals for the Third Circuit
Decided March 28, 1956No. 11443PublishedCited by 35 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
Under long-standing Treasury Regulations a corporation which issues bonds at a discount can prorate or amortize such discount over the life of the bonds.
Sec. 19.22(a)-18(3) (a) of Treasury Regulations Í03, applicable in the tax years here involved, provides:
“If bonds are issued by a corporation at a discount, the net amount of such discount is deductible and should be prorated or amortized over the life of the bonds.”
The instant appeal involves the application of the aforementioned Treasury Regulations.
The undisputed facts, established by the record, may be summarized…
2Cases cited18 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. SmithSupreme Court of the United States · 1940
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
13 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Nassau Lens Co., Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Harry Pildes and Sarah PildesCourt of Appeals for the Second Circuit · 1962
- Chock Full O' Nuts Corporation v. United StatesCourt of Appeals for the Second Circuit · 1971
- Charles D. Long and Gertrude G. Long v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1960
- Jones v. FoxDistrict Court, D. Maryland · 1958
30 more not listed; retrieve them via the Exa API.