Legal Opinion

Houston Lighting & Power Co. v. Commissioner

United States Board of Tax Appeals

Decided July 3, 1936No. Docket No. 74922Published

PUBLIC UTILITY - LIABILITY FOR TAXES. - Petitioner entered into a contract, prior to September 8, 1916, with the city of Houston, Texas, the object and purpose of which was to regulate, operate, and maintain a public utility. Under the terms of the contract, Federal income taxes were to be paid out of the proceeds from operation of the utility prior to any division of the proceeds between petitioner and the city.

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PUBLIC UTILITY - LIABILITY FOR TAXES. - Petitioner entered into a contract, prior to September 8, 1916, with the city of Houston, Texas, the object and purpose of which was to regulate, operate, and maintain a public utility. Under the terms of the contract, Federal income taxes were to be paid out of the proceeds from operation of the utility prior to any division of the proceeds between petitioner and the city. Held, that for the taxable years 1927 to 1930, both inclusive, petitioner is liable for the full amount of the tax levied on the entire undivided fund, under the provisions of…

1Opinion of the Court

HOUSTON LIGHTING & POWER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Houston Lighting & Power Co. v. Commissioner

Docket No. 74922.

United States Board of Tax Appeals

34 B.T.A. 745; 1936 BTA LEXIS 650;

July 3, 1936, Promulgated

PUBLIC UTILITY - LIABILITY FOR TAXES. - Petitioner entered into a contract, prior to September 8, 1916, with the city of Houston, Texas, the object and purpose of which was to regulate, operate, and maintain a public utility. Under the terms of the contract, Federal income taxes were to be paid out of the proceeds from operation of the utility prior…

2Cases cited1 opinion

  1. Houston Lighting & Power Co. v. CommissionerUnited States Board of Tax Appeals · 1936

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