Southern Cailfornia Edison Co. v. Commissioner
United States Tax Court
1. Prior to November 9, 1935, the effective date of Treasury Decision 4603, petitioner retired three issues of bonds with the proceeds from the sale of new bonds. The premium, retirement expense, and unamortized discount on two of the issues were deducted in the year of retirement. Held, the election permissible under T. D. 4603 to prorate such items over the life of the new bonds applies to each separate issue retired prior to November 9, 1935, in a year then open.
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1. Prior to November 9, 1935, the effective date of Treasury Decision 4603, petitioner retired three issues of bonds with the proceeds from the sale of new bonds. The premium, retirement expense, and unamortized discount on two of the issues were deducted in the year of retirement. Held, the election permissible under T. D. 4603 to prorate such items over the life of the new bonds applies to each separate issue retired prior to November 9, 1935, in a year then open. The failure to make an election on the retirement of the two issues did not bar an election on the third bond issue. 2. When the…
1Opinion of the Court
Southern California Edison Company, Ltd., Petitioner, v. Commissioner of Internal Revenue, Respondent
Southern Cailfornia Edison Co. v. Commissioner
Docket Nos. 708, 3382
United States Tax Court
4 T.C. 294; 1944 U.S. Tax Ct. LEXIS 26;
November 8, 1944, Promulgated
Decision will be entered under Rule 50.
1. Prior to November 9, 1935, the effective date of Treasury Decision 4603, petitioner retired three issues of bonds with the proceeds from the sale of new bonds. The premium, retirement expense, and unamortized discount on two of the issues were deducted in the year of retirement. Held, the election…
2Cases cited3 opinions
- Bell County v. LightfootTexas Supreme Court · 1911
- Pyle v. ClarkU.S. Circuit Court for the District of Utah · 1896
- Southern Cailfornia Edison Co. v. CommissionerUnited States Tax Court · 1944