Scott Paper Co. v. Commissioner
United States Tax Court
Scott issued debentures which were convertible into shares of common stock. Interest on the debentures was paid twice yearly, on Mar. 1 and Sept. 1. Scott, a calendar year, accrual method taxpayer, annually deducted interest pursuant to sec. 163, I.R.C. 1954, in an amount equal to the sum of (1) interest accrued from Jan. 1 to Dec. 31 on debentures which were not converted during that taxable year; and (2) interest accrued from Jan. 1 to the date of conversion on debentures…
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Scott issued debentures which were convertible into shares of common stock. Interest on the debentures was paid twice yearly, on Mar. 1 and Sept. 1. Scott, a calendar year, accrual method taxpayer, annually deducted interest pursuant to sec. 163, I.R.C. 1954, in an amount equal to the sum of (1) interest accrued from Jan. 1 to Dec. 31 on debentures which were not converted during that taxable year; and (2) interest accrued from Jan. 1 to the date of conversion on debentures which were converted during that taxable year. Respondent disallowed that part of the claimed interest deduction which…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in the Federal income tax of petitioner as follows:
Taxable Docket No. year Deficiency
1775-73 1961 $111,876
1962 17,155
1963 14,968
1964 23,303
Taxable Docket No. year Deficiency
2897-74 1965 $225,950
1966 98,888
1967 70,274
1968 116,386
19691 98,552
These cases have been consolidated for trial, briefs, and opinion. The issues presented for our decision are:(1) Whether petitioner is entitled to deduct interest on converted debentures which accrued from the last interest payment date to the date of conversion; and if so, whether the conversion of…
2Cases cited38 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- United States v. AndersonSupreme Court of the United States · 1926
- Higgins v. SmithSupreme Court of the United States · 1940
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
33 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Skripak v. CommissionerUnited States Tax Court · 1985
- Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980
- Illinois Cereal Mills, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Bennett Paper Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 1982
- A. C. Monk & Company, Inc. v. The United States of America, A. C. Monk & Company, Inc. v. The United States of AmericaCourt of Appeals for the Fourth Circuit · 1982
36 more not listed; retrieve them via the Exa API.