Legal Opinion

Montana Power Co. v. United States

District Court, D. New Jersey

Decided May 17, 1954No. Civ. A. No. 159-52PublishedCited by 6 opinions

1Opinion of the Court

HARTSHORNE, District Judge.

The question in this case is whether or not the debentures of plaintiff Montana Power, “Montana”, were issued at a discount, and, if so, whether or not such discount is to be determined and deducted in Montana’s income and excess profits tax returns, according to the principle laid down in American Smelting & Refining Co. v. United States, 3 Cir., 1942, 130 F.2d 883. The pertinent principle stated in that case is that, in ascertaining the existence of bond discount for Federal tax purposes the discount is “the difference [between] the par value of [the] bonds and…

2Cases cited8 opinions

  1. Healy v. CommissionerSupreme Court of the United States · 1953
  2. Old Mission Portland Cement Co. v. HelveringSupreme Court of the United States · 1934
  3. Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
  4. Helvering v. Union Pacific RailroadSupreme Court of the United States · 1934
  5. Founders General Corp. v. HoeySupreme Court of the United States · 1937

3 more not listed; retrieve them via the Exa API.

3Cited by6 opinions

  1. The Montana Power Company v. United StatesCourt of Appeals for the Third Circuit · 1956
  2. Montana Power Co. v. United StatesUnited States Court of Claims · 1958
  3. Arthur Imerman Undergarment Corp. v. LOCAL 162, ETC.District Court, D. New Jersey · 1956
  4. In re Gravure Paper & Board Corp.District Court, D. New Jersey · 1957
  5. The Montana Power Company v. United StatesCourt of Appeals for the Third Circuit · 1956

1 more not listed; retrieve them via the Exa API.

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