Legal Opinion
Commissioner of Int. Rev. v. Pittsburgh & WV Ry. Co.
Court of Appeals for the Third Circuit
Decided February 9, 1949No. 9632PublishedCited by 4 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
This appeal is taken from the decision of the Tax Court.
The single question presented is whether the taxpayer realized taxable income in the taxable years 1941 and 1942 when it purchased in the open market its own first mortgage bonds at a cost less than the issue price and immediately, pursuant tO' its covenants in a junior trust indenture, deposited and pledged the purchased bonds with the trustee as additional collateral to the junior note issue.
'The facts as found by the Tax Court 1 may be summarized as follows :
The taxpayer is a corporation, organized under the…
2Cases cited17 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. HallockSupreme Court of the United States · 1940
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Brewster v. GageSupreme Court of the United States · 1930
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
12 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Harold Wener v. Commissioner of Internal Revenue, Molly Wener v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- Thompson v. Commissioner of Internal Revenue. Couse v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- Pacific Magnesium, Inc. v. WestoverDistrict Court, S.D. California · 1949
- Sharon Herald Co. v. GrangerDistrict Court, W.D. Pennsylvania · 1951