Oswego & S. R. Co. v. Commissioner
United States Board of Tax Appeals
1. Where money was borrowed for construction purposes and was so used, interest thereon and discounts therefrom attributable to the period of construction were not for the purposes of invested capital a part of the cost of construction. 2. Section 201 of the Revenue Act of 1918 applied.
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1. Where money was borrowed for construction purposes and was so used, interest thereon and discounts therefrom attributable to the period of construction were not for the purposes of invested capital a part of the cost of construction. 2. Section 201 of the Revenue Act of 1918 applied. Where a dividend made during the first 60 days of a taxable year can be paid only from earnings and profits accumulated prior to March 1, 1913, or from a rental accruing in the taxable year and the previous year, such dividend should be allocated to the whole period for which the rent was accruing and so much…
1Opinion of the Court
OSWEGO & SYRACUSE RAILROAD CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Oswego & S. R. Co. v. Commissioner
Docket No. 8157.
United States Board of Tax Appeals
9 B.T.A. 904; 1927 BTA LEXIS 2493;
December 27, 1927, Promulgated
1. Where money was borrowed for construction purposes and was so used, interest thereon and discounts therefrom attributable to the period of construction were not for the purposes of invested capital a part of the cost of construction.
2. Section 201 of the Revenue Act of 1918 applied. Where a dividend made during the first 60 days of a taxable year can be…
2Cases cited12 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- McCardle v. Indianapolis Water Co.Supreme Court of the United States · 1926
- Mason v. RoutzahnSupreme Court of the United States · 1927
- Walsh v. BrewsterSupreme Court of the United States · 1921
- Hays v. Gauley Mountain Coal Co.Supreme Court of the United States · 1918
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