Philadelphia Transp. Co. v. Commissioner
United States Tax Court
A plan of reorganization under section 77-B of the Bankruptcy Act, approved November 14, 1939, provided for merger and consolidation of 65 companies previously constituting the Philadelphia Rapid Transit Co. System into a new company to be incorporated, the petitioner herein.
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A plan of reorganization under section 77-B of the Bankruptcy Act, approved November 14, 1939, provided for merger and consolidation of 65 companies previously constituting the Philadelphia Rapid Transit Co. System into a new company to be incorporated, the petitioner herein. It also provided that the new company, upon incorporation, should issue to holders of stock and stock trust certificates of certain of the merged companies, its 3 per cent-6 per cent consolidated mortgage bonds dated January 1, 1939, and bearing interest from that date. Petitioner's corporate existence began on January…
1Opinion of the Court
OPINION.
Harlan, Judge:
The respondent contends that the payments made by petitioner in the redemption of the 1939 coupons were not payments of interest;.that the obligation to redeem the 1939' coupons did not accrue in 1940; that it was imposed in 1939 and became a fixed liability on November 14, 1939; that the 1939 coupons were to counterbalance the difference between 1939 rentals and the $700,000 ad interim payment ; that the amount of $1,787,206.88 paid to redeem the 1939 coupons was computed on 1939 income; that it is treated on petitioner’s books exactly in accordance with respondent’s…
2Cases cited4 opinions
- Magruder v. SuppleeSupreme Court of the United States · 1942
- Koppers Co. v. CommissionerUnited States Tax Court · 1944
- Ernst Kern Co. v. CommissionerUnited States Tax Court · 1942
- Rodney, Inc. v. CommissionerUnited States Tax Court · 1943
3Cited by1 opinion
- Philadelphia Transp. Co. v. CommissionerUnited States Tax Court · 1947