Legal Opinion

Liquid Carbonic Corp. v. Commissioner

United States Board of Tax Appeals

Decided October 22, 1936No. Docket Nos. 50985, 61319, 72270Published

1. Petitioner retired some of its outstanding bonds by exchanging therefor shares of its capital stock. Held, the amount of the unamortized bond discount and expenses attributable to the bonds retired in that manner was not deductible from gross income during the years of retirement. 2. Commissions paid for underwriting shares of petitioner's capital stock used in an exchange for some of its outstanding bonds and their retirement held not allowable as deductions from gross…

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1. Petitioner retired some of its outstanding bonds by exchanging therefor shares of its capital stock. Held, the amount of the unamortized bond discount and expenses attributable to the bonds retired in that manner was not deductible from gross income during the years of retirement. 2. Commissions paid for underwriting shares of petitioner's capital stock used in an exchange for some of its outstanding bonds and their retirement held not allowable as deductions from gross income. 3. Where petitioner, by action of its board of directors, voted to pay its employees additional compensation at…

1Opinion of the Court

THE LIQUID CARBONIC CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Liquid Carbonic Corp. v. Commissioner

Docket Nos. 50985, 61319, 72270.

United States Board of Tax Appeals

34 B.T.A. 1191; 1936 BTA LEXIS 584;

October 22, 1936, Promulgated

1. Petitioner retired some of its outstanding bonds by exchanging therefor shares of its capital stock. Held, the amount of the unamortized bond discount and expenses attributable to the bonds retired in that manner was not deductible from gross income during the years of retirement.

2. Commissions paid for underwriting shares of…

2Cases cited6 opinions

  1. Helvering v. Union Pacific RailroadSupreme Court of the United States · 1934
  2. Pierce Oil Corp. v. CommissionerUnited States Board of Tax Appeals · 1935
  3. Chicago, Rock Island & Pacific Railway Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  4. Package Machinery Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  5. Allyne-Zerk Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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