Baltimore & Ohio R.R. v. Commissioner
United States Board of Tax Appeals
1. Reductions from the recited figure above par, at which a corporation offers shares of stock, equal to 6 percent on the par value of the share between date of offer and date of issuance, do not constitute interest paid by the corporation. 2. Amounts paid to bankers and the costs of printing and listing, all of which are incidental to the issuance of common shares, are not deductible by the issuing corporation as ordinary and necessary expenses. 3. Value on March 1, 1913,…
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1. Reductions from the recited figure above par, at which a corporation offers shares of stock, equal to 6 percent on the par value of the share between date of offer and date of issuance, do not constitute interest paid by the corporation. 2. Amounts paid to bankers and the costs of printing and listing, all of which are incidental to the issuance of common shares, are not deductible by the issuing corporation as ordinary and necessary expenses. 3. Value on March 1, 1913, of shore lands on Staten Island, New York, determined. 4. The amount of an award, and interest thereon, upon the…
1Opinion of the Court
*371OPINION.
Sternhagen:
1. The petitioner claims three classes of deductions growing out of its issue of common shares in 1927: (a) $422,927.40, which it calls interest on prepaid stock subscriptions; (b) $1,422,-956.25 underwriting and service fees to the bankers, and (c) $17,-053.80 printing and listing costs. In our opinion, none of these amounts is a proper deduction under the statute, Revenue Act of 1926, section 234, and the decision as to each is governed by prior decisions.
*372(a) Despite the petitioner’s characterization in the notice to shareholders of the subscription price as the full…
2Cases cited7 opinions
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Anderson & Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Bliss v. CommissionerUnited States Board of Tax Appeals · 1933
- Daniel Bros. Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Marsh & Marsh, Inc. v. CommissionerUnited States Board of Tax Appeals · 1926
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Firemen's Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Clark Oil & Refining Corp. v. United StatesDistrict Court, E.D. Wisconsin · 1971
- Baltimore & Ohio R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
- Firemen's Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
2 more not listed; retrieve them via the Exa API.