Carding Gill, Ltd. v. Commissioner
United States Board of Tax Appeals
Petitioner, a foreign corporation, held taxable on the profit from security sales in the United States; held, further, not entitled to deductions for discount on the issuance of its own bonds in the absence of proof of the value of property received in exchange.
1Opinion of the Court
*671OPINION.
Opper :
The three issues in this proceeding, while interrelated, may be stated separately: First, whether petitioner, being a foreign corporation, is subject to tax upon its income from the sale of securities in the United States; second, whether it is entitled to deductions for amortization of bond discount more than equal to any income from sources within the United States; and, third, whether it is subject to the 25 percent additional tax for delinquency in the filing of its return.
On the first question, petitioner urges that section 119 (a) of the Revenue Act of 19281 does not have…
2Cited by10 opinions
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- American Smelting & Refining Co. v. United StatesCourt of Appeals for the Third Circuit · 1942
- American Smelting & Refining Co. v. United StatesDistrict Court, D. New Jersey · 1941
- Abilene Life Ins. Co. v. CommissionerUnited States Tax Court · 1943
- American Smelting & Refining Co. v. United StatesCourt of Appeals for the Third Circuit · 1942
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