Legal Opinion

Congress Square Hotel Co. v. Commissioner

United States Tax Court

Decided February 13, 1945No. Docket No. 4277Published

Petitioner entered into a contract with certain underwriters to sell to them a new issue of bonds. Pursuant thereto payment was made by check and the bonds delivered to the underwriters. The check, together with additional cash and the old bonds then in petitioner's treasury, was used to discharge the mortgage and retire the old bonds.

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Petitioner entered into a contract with certain underwriters to sell to them a new issue of bonds. Pursuant thereto payment was made by check and the bonds delivered to the underwriters. The check, together with additional cash and the old bonds then in petitioner's treasury, was used to discharge the mortgage and retire the old bonds. The underwriters agreed to offer a like amount of new bonds to old bondholders at the call price of the old bonds for a limited time, thereafter to others at a specified higher price. The old bondholders surrendered their bonds to a designated bank acting as…

1Opinion of the Court

Congress Square Hotel Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Congress Square Hotel Co. v. Commissioner

Docket No. 4277

United States Tax Court

4 T.C. 775; 1945 U.S. Tax Ct. LEXIS 228;

February 13, 1945, Promulgated

Decision will be entered under Rule 50.

Petitioner entered into a contract with certain underwriters to sell to them a new issue of bonds. Pursuant thereto payment was made by check and the bonds delivered to the underwriters. The check, together with additional cash and the old bonds then in petitioner's treasury, was used to discharge the mortgage and…

2Cases cited2 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

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