Legal Opinion
Dayton & Michigan R. v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided June 10, 1940No. 4602PublishedCited by 20 opinions
1Opinion of the Court
PARKER, Circuit Judge.
This is a petition to review a decision of the Board of Tax Appeals. The sole question involved, is whether payments of guaranteed dividends on preferred stock of petitioner are deductible as interest paid on indebtedness within the meaning of Sec. 23(b) of the Revenue Act of 1934, 48 Stat. 680, 26 U.S.C.A. Int.Rev.Code, § 23(b). These guaranteed dividends were paid by the Baltimore and Ohio Railroad Company, as assignee of the lessee of the properties of petitioner, direct to the stockholders. There is no' question but that such payments constituted income to the…
2Cases cited18 opinions
- Erie Railroad v. TompkinsSupreme Court of the United States · 1938
- Blair v. CommissionerSupreme Court of the United States · 1937
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Lindsey v. WashingtonSupreme Court of the United States · 1937
- Tyler v. United StatesSupreme Court of the United States · 1930
13 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Commissioner of Int. Rev. v. Meridian & Thirteenth R. Co.Court of Appeals for the Seventh Circuit · 1942
- Helvering v. CampbellCourt of Appeals for the Fourth Circuit · 1944
- McClaskey v. Harbison-Walker Refractories Co.Court of Appeals for the Third Circuit · 1943
- Legg's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1940
- Momand v. Twentieth-Century Fox Film CorporationDistrict Court, W.D. Oklahoma · 1941
15 more not listed; retrieve them via the Exa API.