Monon Railroad v. Commissioner
United States Tax Court
The petitioner, a publicly owned corporation, issued 50-year 6-percent income debentures in exchange for most of the outstanding stock of one class. Interest on the debentures was accrued and paid for a period of 15 months prior to their issuance. Held, the debentures are instruments of indebtedness on which interest is deductible when accrued, including the interest attributed to the 15-month period prior to issuance.
1Opinion of the Court
Simpson, Judge:
The respondent determined deficiencies in the income tax of the petitioner as follows:
TYB. Dec. SI— Deficiency
1953 _$10, 701. 85
1954 _ 78,943.98
1955 _ 387, 851. 04
1956 _ 325, 324. 92
The respondent also redetermined the petitioner’s income for the taxable years ended December 31, 1957, December 31, 1958, and December 31, 1959. In each of these 3 years, the petitioner incurred a loss according to both its income tax return and the respondent’s statement of adjustment; however, the respondent’s redeterminations for such years affected the net operating loss carryback available for…
2Cases cited42 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. TowerSupreme Court of the United States · 1946
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
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3Cited by14 opinions
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- Investors Insurance Agency, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Rutter v. Comm'rUnited States Tax Court · 2017
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