Legal Opinion

South Carolina Continental Tel. Co. v. Commissioner

United States Tax Court

Decided January 28, 1948No. Docket No. 10212Published

Held, that the transactions here involved between petitioner and the holder of all its outstanding old bonds did not constitute purchase and sale transactions, but an exchange or substitution of new bonds for old as evidence of a continuing indebtedness between the same parties; held, further, that the premium paid and unamortized discount and expense upon retirement of the old bonds in 1941 are not deductible in full in that year, but should be amortized over the life of…

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Held, that the transactions here involved between petitioner and the holder of all its outstanding old bonds did not constitute purchase and sale transactions, but an exchange or substitution of new bonds for old as evidence of a continuing indebtedness between the same parties; held, further, that the premium paid and unamortized discount and expense upon retirement of the old bonds in 1941 are not deductible in full in that year, but should be amortized over the life of the new bonds issued in exchange for the old.

1Opinion of the Court

South Carolina Continental Telephone Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

South Carolina Continental Tel. Co. v. Commissioner

Docket No. 10212

United States Tax Court

10 T.C. 164; 1948 U.S. Tax Ct. LEXIS 279;

January 28, 1948, Promulgated

Decision will be entered under Rule 50.

Held, that the transactions here involved between petitioner and the holder of all its outstanding old bonds did not constitute purchase and sale transactions, but an exchange or substitution of new bonds for old as evidence of a continuing indebtedness between the same parties; held, further,…

2Cases cited4 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
  4. South Carolina Continental Tel. Co. v. CommissionerUnited States Tax Court · 1948

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