Michigan Cent. R.R. v. Commissioner
United States Board of Tax Appeals
1. In 1917 the New York Central Railroad Co. paid to a wholly owned subsidiary coal corporation $309,244.64 to enable that corporation to carry certain unused coal lands as an investment.
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1. In 1917 the New York Central Railroad Co. paid to a wholly owned subsidiary coal corporation $309,244.64 to enable that corporation to carry certain unused coal lands as an investment. Held, the payment is not deductible as an ordinary and necessary expense. 2. An amount paid to the State of Illinois pursuant to state statute upon the issuance of petitioner's bonds, held deductible as taxes paid. 3. Where bonds were issued at a discount by corporations, predecessors of this taxpayer, held, that the petitioner is not entitled to deductions for the amortization of such discount. 4. The…
1Opinion of the Court
*438OPINION.
Smith:
These proceedings, duly consolidated, are for the rede-termination of the following income tax deficiencies:
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The respondent, having made several affirmative allegations, duly asserts claim to any increase in the deficiencies that may result from our redetermination.
The Michigan Central Eailroad Co. is a corporation organized under the laws of the State of Michigan. The New York Central Railroad Co. is a corporation organized under the laws of the State of New York and other states. Both petitioners maintained offices at 466 Lexington Avenue, New York City. At all…
2Cases cited24 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Weiss v. WeinerSupreme Court of the United States · 1929
- Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
- Holeproof Hosiery Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Emerson Electric Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1926
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3Cited by11 opinions
- Downer v. CommissionerUnited States Tax Court · 1967
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- Pittsburgh Indus. Eng'g Co. v. CommissionerUnited States Tax Court · 1950
- Cook v. CommissionerUnited States Board of Tax Appeals · 1934
- Illinois C. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
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