Legal Opinion
National City Lines, Inc. v. United States
Court of Appeals for the Third Circuit
Decided August 5, 1952No. 10520_1PublishedCited by 13 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
The sole question presented by this appeal is whether payments received by a taxpayer, representing interest for periods prior to its “flat” 1 purchase of certain securities, should be treated as a return of capital or as taxable income.
The pertinent facts are as follows:
The St. Louis Public Service Company, a Missouri transportation corporation, as a result of reorganization proceedings under Section 77B of the Bankruptcy Act, 11 U.S.C.A. § 207, issued in 1939 certain securities consisting of $15,865,000 twenty-five year convertible income bonds and $4,-200,655…
2Cases cited9 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Pierce Estates, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- Clyde C. Pierce Corp. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1941
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Simon Jaglom and Marie Jaglom v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Shattuck v. CommissionerUnited States Tax Court · 1955
- Graham v. CommissionerUnited States Tax Court · 1961
- First Kentucky Company v. GrayDistrict Court, W.D. Kentucky · 1960
- Rickaby v. CommissionerUnited States Tax Court · 1957
8 more not listed; retrieve them via the Exa API.