Legal Opinion

South Carolina Continental Telephone Co. v. Commissioner

United States Tax Court

Decided January 28, 1948No. Docket No. 10212PublishedCited by 4 opinions

1Opinion of the Court

OPINION.

Tyson, Judge:

The first assignment of error presents the only remaining issue for our redetermination. The parties are in agreement as to the principles of law applicable to that issue, viz., that, generally, where an outstanding issue of bonds is retired for cash, even though the cash is obtained by the sale of a new issue of bonds, the premium paid upon the retirement and the unamortized discount and expenses of the old bonds are deductible in the year of retirement,1 but that where an outstanding issue of bonds is retired by an exchange Or substitution of old bonds for new, those…

2Cases cited3 opinions

  1. Great Western Power Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
  2. Congress Square Hotel Co. v. CommissionerUnited States Tax Court · 1945
  3. Southern Cailfornia Edison Co. v. CommissionerUnited States Tax Court · 1944

3Cited by4 opinions

  1. Bridgeport Hydraulic Co. v. CommissionerUnited States Tax Court · 1954
  2. Bridgeport Hydraulic Co. v. CommissionerUnited States Tax Court · 1954
  3. Durham Tel. Co. v. CommissionerUnited States Tax Court · 1948
  4. Union Tel. Co. v. CommissionerUnited States Tax Court · 1948

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