Liberty Light & Power Co. v. Commissioner
United States Board of Tax Appeals
In conformity with the statutes of the States of Indiana and Ohio, certain citizens desiring to obtain electric service constructed certain transmission lines at a cost of $10,500 and transferred the same to the taxpayer which was required, by statute and regulations of the Public Utilities Commission, thereafter to maintain said lines and to furnish electrical current to the subscribers to the cost of constructing said line, and, to such other subscribers for electrical…
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In conformity with the statutes of the States of Indiana and Ohio, certain citizens desiring to obtain electric service constructed certain transmission lines at a cost of $10,500 and transferred the same to the taxpayer which was required, by statute and regulations of the Public Utilities Commission, thereafter to maintain said lines and to furnish electrical current to the subscribers to the cost of constructing said line, and, to such other subscribers for electrical service upon the payment of the cost of equipment necessary to make connection with said lines, at rates to be prescribed…
1Opinion of the Court
*159OPINION.
Littleton:
The issue presented in this appeal is similar to that before the court in the case of Edwards v. Cuba R. R. Co., 268 U. S. 628, and is whether certain electric power lines constructed by the citizens of Indiana and Ohio and transferred upon completion to the taxpayer, becoming its property under the provisions of the statutes of Indiana and Ohio, constituted taxable income within the meaning of the Sixteenth Amendment to the Constitution and the Revenue Act of 1921.
The question of what constitutes income within the meaning of the Sixteenth Amendment and the various revenue…
2Cases cited17 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- United States v. PhellisSupreme Court of the United States · 1921
- Weiss v. StearnSupreme Court of the United States · 1924
- Southern Pacific Co. v. LoweSupreme Court of the United States · 1918
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3Cited by16 opinions
- Teleservice Company of Wyoming Valley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Arundel-Brooks Concrete Corp. v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1942
- Baltimore & O. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Electric Energy, Inc. v. United StatesUnited States Court of Claims · 1987
- Hayutin v. CommissionerUnited States Tax Court · 1972
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