Union Pac. R.R. v. Commissioner
United States Board of Tax Appeals
1. DONATIONS. Petitioners received donations for construction of facilities and entered into contracts with the donors providing for the refund of the donations on the basis of the amount of revenue freight shipped by the donors within a specified period of time. Upon the expiration of the agreed period amounts unrefunded were forfeited by the donors. Held the amounts so forfeited do not constitute income. 2. INCOME.
Read the full summary
1. DONATIONS. Petitioners received donations for construction of facilities and entered into contracts with the donors providing for the refund of the donations on the basis of the amount of revenue freight shipped by the donors within a specified period of time. Upon the expiration of the agreed period amounts unrefunded were forfeited by the donors. Held the amounts so forfeited do not constitute income. 2. INCOME. Compensation received in settlement of the Government guaranty for the period following Federal control held to constitute taxable income. 3. DEDUCTION - 2 PER CENT INCOME TAX.…
1Opinion of the Court
OPINION.
Arundell:
These proceedings involve deficiencies in income taxes of the Union Pacific Railroad Company and its affiliated corporations for the years 1920 to 1923, inclusive, in an aggregate amount of $1,617,423. Docket No. 40002 is a transferee proceeding, which the parties agree is disposed of by their stipulation that any deficiency shall be allocated wholly to the parent, the Union Pacific Railroad Company. The transferee liability asserted by the respondent is in, the amount of $3,220.25.
The petitions filed allege 25 errors, of which 14, and an affirmative defense presented by…
2Cases cited5 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Texas & Pacific Ry. Co. v. United StatesSupreme Court of the United States · 1932
3Cited by13 opinions
- Michigan Cent. R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
- Baltimore & O. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Pittsburgh & Lake Erie R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
- Ann Arbor R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
- Southern Ry. Co. v. CommissionerCourt of Appeals for the Fourth Circuit · 1936
8 more not listed; retrieve them via the Exa API.