Legal Opinion

Montana, W. & S. R. Co. v. Commissioner

United States Board of Tax Appeals

Decided August 9, 1934No. Docket No. 71486Published

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

MONTANA, WYOMING & SOUTHERN RAILROAD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Montana, W. & S. R. Co. v. Commissioner

Docket No. 71486.

United States Board of Tax Appeals

31 B.T.A. 62; 1934 BTA LEXIS 1173;

August 9, 1934, Promulgated

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.

Henry J. Richardson, Esq., for the petitioner

Paul A. Sebastian, Esq., for the…

2Cases cited1 opinion

  1. Montana, W. & S. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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