Tennessee, Alabama & Georgia Ry. Co. v. Commissioner of Internal Revenue

MARTIN, Circuit Judge.

This tax review involving complicated transactions and the applicability or inapplicability of numerous sections and subsections of the Internal Revenue Code analyzes to a single issue: Did the United States Tax Court, in determining the equity invested capital of a newly organized railroad corporation for excess profits tax purposes, correctly hold that a series of transactions leading to its set-up constituted integrated steps and parts of a single overall plan?

The Tax Court, in its findings of fact and opinion (reviewed by the Court) published in 13 T.C. 486 (Case No.…