Legal Opinion
Richard Drayton, John R. Sauerteig, and Sydney G. Stevens, as Escrow Agents of the Delaware & Bound Brook Railroad Company v. United States
Court of Appeals for the Third Circuit
Decided October 7, 1986No. 85-5432PublishedCited by 5 opinions
1Opinion of the Court
OPINION OF THE COURT
BECKER, Circuit Judge.
This income tax case arises in the aftermath of the Rail Reorganization Act. Before us on an appeal from the judgment of the district court in a tax refund suit, it requires us to determine the proper income tax treatment of the interest component of certificates of value delivered to the shareholders of the transferor railroads as compensation for their properties. The district court ruled that the interest component was non-taxable pursuant to 26 U.S.C. § 374(c) (1982). We disagree, however, and hold that the income is fully taxable as ordinary…
2Cases cited8 opinions
- Regional Rail Reorganization Act CasesSupreme Court of the United States · 1974
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Burnet v. LoganSupreme Court of the United States · 1931
- Kieselbach v. CommissionerSupreme Court of the United States · 1943
- Fall River Electric Light Co. v. CommissionerUnited States Board of Tax Appeals · 1931
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3Cited by5 opinions
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- Mitchell v. Commission on Adult Entertainment Establishments of DelawareDistrict Court, D. Delaware · 1991
- Emmerson v. WalkerMontana Supreme Court · 2010