Montana, W. & S. R. Co. v. Commissioner
United States Board of Tax Appeals
When a corporation, keeping its books on the accrual basis, purchases a quantity of its first mortgage bonds at a price less than the issuing price, the excess of the issue price over the purchase price is taxable gain to the corporation for the year of purchase.
1Opinion of the Court
OPINION.
Aeundell :
The taxes in controversy here relate to the year 1930 and amount to $1,820.10. An original deficiency of $4,367.52 for the year 1930 was determined by the respondent, of which sum the petitioner paid $2,547.42. In its petition the petitioner states that it reserves the right to claim and recover refund of this sum paid, but fails to make further issue respecting it, either at the hearing or in its brief. This part of the tax will, therefore, be disregarded in this report.
This case has been submitted upon a stipulation of facts filed by the parties at the hearing, and we set…
2Cases cited6 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Helvering v. American Chicle Co.Supreme Court of the United States · 1934
- Garland Coal & Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Consolidated Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Virginia Iron, Coal & Coke Co. v. CommissionerUnited States Board of Tax Appeals · 1934
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Corporacion de Ventas de Salitre y Yoda v. CommissionerUnited States Board of Tax Appeals · 1941
- Montana, W. & S. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Tennessee Consol. Coal Co. v. CommissionerUnited States Tax Court · 1943
- Transylvania R. Co. v. CommissionerUnited States Board of Tax Appeals · 1937