Legal Opinion

Railway Express Agency, Inc. v. Commissioner

United States Tax Court

Decided May 13, 1947No. Docket No. 7886Published

The stock of the petitioner, organized to conduct an express business, is owned by about 70 railroads. It has individual contracts with about 400 railroads (including the 70) under which it accounts to them proportionately for the net revenues of the business. It issued its own bonds in the amount of $ 32,000,000 for purchase of property and operating capital. None of the railroads agreed to pay its expenses.

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The stock of the petitioner, organized to conduct an express business, is owned by about 70 railroads. It has individual contracts with about 400 railroads (including the 70) under which it accounts to them proportionately for the net revenues of the business. It issued its own bonds in the amount of $ 32,000,000 for purchase of property and operating capital. None of the railroads agreed to pay its expenses. The contracts refer to the payments made to the railroads as compensation. Additional property acquired with revenues is not shown to belong to the railroads. Held, the petitioner is not…

1Opinion of the Court

Railway Express Agency, Incorporated, Petitioner, v. Commissioner of Internal Revenue, Respondent

Railway Express Agency, Inc. v. Commissioner

Docket No. 7886

United States Tax Court

8 T.C. 991; 1947 U.S. Tax Ct. LEXIS 206;

May 13, 1947, Promulgated

Decision will be entered under Rule 50.

The stock of the petitioner, organized to conduct an express business, is owned by about 70 railroads. It has individual contracts with about 400 railroads (including the 70) under which it accounts to them proportionately for the net revenues of the business. It issued its own bonds in the amount of $ 32,000,000…

2Cases cited10 opinions

  1. Helvering v. HorstSupreme Court of the United States · 1940
  2. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  3. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  4. Commissioner v. WilcoxSupreme Court of the United States · 1946
  5. Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940

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