Southern Pacific Co. v. Commissioner

*411OPINION.

Green:

These matters came on for rehearing on the respondent’s motion to dismiss for lack of jurisdiction. Each of the above-named petitioners had outstanding in the year 1921, certain tax-free covenant bonds, some of which were in the hands of nonresident aliens. These aliens, for reasons not disclosed by the record, failed to collect their annual interest when the same became due, and in the year 1921, in the case of the Southern Pacific Co. and 1923 in the other two cases, these petitioners paid to such bondholders the interest which had accumulated over a number of years. In some…