Chicago & N. W. R. Co. v. Commissioner
United States Tax Court
1. Petitioner owned 93.66 per cent of the stock of a railroad company referred to as Omaha. In 1929 Omaha had obligations amounting to $ 45,186,000 which would mature in 1930. At that time, Omaha's credit would not permit a refinancing without the guaranty of petitioner.
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1. Petitioner owned 93.66 per cent of the stock of a railroad company referred to as Omaha. In 1929 Omaha had obligations amounting to $ 45,186,000 which would mature in 1930. At that time, Omaha's credit would not permit a refinancing without the guaranty of petitioner. Petitioner, in 1929, issued $ 72,335,000 of its own 4 3/4 per cent bonds and loaned $ 45,186,000 of the proceeds of this issue to Omaha, and took Omaha's note which was later exchanged for $ 45,186,000 of Omaha's 5 per cent bonds. Both petitioner and Omaha reported on an accrual basis. Petitioner accrued and reported as…
1Opinion of the Court
OPINION.
Arundell, Judge:
Respondent determined deficiencies in income and surtaxes for tlie calendar years 1942 and 1943 in the amounts of $331,198.28 and $303,689.61, respectively. Petitioner claims there are no deficiencies and that it is entitled to a refund in each year. Respondent, on the other hand, has made claim for increased deficiencies under section 272 (e) of the Internal Revenue Code of 1939.1 The years 1940 and 1941 are also involved in connection with a net operating loss carryover deduction from those years to the taxable year 1942.
The pleadings raised a large number of issues,…
2Cases cited17 opinions
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- Corn Exchange Bank v. United StatesCourt of Appeals for the Second Circuit · 1930
- Boston & M.R.R. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953
- Burton Swartz Land Corp v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
- Atlantic Coast Line R. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1936
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3Cited by36 opinions
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