Legal Opinion
Missouri Pacific Railroad Company v. The United States
United States Court of Claims
Decided October 16, 1964No. 499-59PublishedCited by 8 opinions
1Opinion of the Court
LARAMORE, Judge.
This is an action for the refund of Federal income taxes for the year 1954 in the amount of $2,480,183.29, together with deficiency interest in the amount of $121,182.52, plus statutory interest on these amounts. The question presented centers on the deductibility under section 163 of the 1954 Code 1 of so-called “preissue” interest resulting from a railroad insolvency reorganization. 2
The Missouri Pacific Railroad Company, the taxpayer here, has been continuously engaged in operating a railroad in interstate commerce since its organization in 1917. From July 1, 1933 to March…
2Cases cited11 opinions
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
- Commissioner v. Philadelphia Transportation Co.Supreme Court of the United States · 1949
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Missouri Pacific Railroad Company v. The United StatesUnited States Court of Claims · 1970
- Estate of Hugh Gordon Miller, Deceased, Allen Gordon Miller, Edwin Schroff and Helen T. Ives v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Estate of Edna Allen Miller, Deceased, Allen Gordon Miller and Erwin SchroffCourt of Appeals for the Third Circuit · 1968
- Knapp King-Size Corp. v. United StatesUnited States Court of Claims · 1975
- Central & South West Corporation v. BrownDistrict Court, D. Delaware · 1965
- State Department of Assessments & Taxation v. Loyola Federal Savings & Loan Ass'nCourt of Special Appeals of Maryland · 1989
3 more not listed; retrieve them via the Exa API.