Columbus & Southern Ohio Electric Co. v. Commissioner
United States Tax Court
Petitioner, a public utility in Ohio, appealed to the State Public Utilities Commission from a 1949 ordinance of the City of Columbus fixing lower rates. The utility collected at the former rates under bond to make refunds of collections in excess of the rates ultimately to be fixed. The City enacted a new ordinance in 1950 which fixed higher rates and authorized the filing of a stipulation of settlement with the commission.
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Petitioner, a public utility in Ohio, appealed to the State Public Utilities Commission from a 1949 ordinance of the City of Columbus fixing lower rates. The utility collected at the former rates under bond to make refunds of collections in excess of the rates ultimately to be fixed. The City enacted a new ordinance in 1950 which fixed higher rates and authorized the filing of a stipulation of settlement with the commission. Petitioner accepted the ordinance in 1950. In 1951 the stipulation was filed, the commission entered an order pursuant to the accepted ordinance, and refunds were made in…
1Opinion of the Court
OPINION.
Tiet jens, Judge:
Respondent determined a deficiency in income tax for 1951 in the amount of $601,859.16. Some of the respondent’s adjustments are not contested. The sole issue is whether petitioner is entitled to accrue a deduction for rate differential refunds in 1951. The facts are stipulated. The petitioner filed its corporation income tax return with the collector of internal revenue at Columbus, Ohio.
The facts are found as stipulated and the exhibits are incorporated by this reference.
The petitioner is an Ohio corporation and is a public utility, as defined in the laws of Ohio,…
2Cases cited10 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- United States v. Safety Car Heating & Lighting Co.Supreme Court of the United States · 1936
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3Cited by7 opinions
- Commissioner of Internal Revenue v. Fifth Avenue Coach Lines, Inc., Fifth Avenue Coach Lines, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Fifth Ave. Coach Lines,Inc. v. CommissionerUnited States Tax Court · 1959
- Midwest Motor Express, Inc. v. CommissionerUnited States Tax Court · 1956
- Columbus & Southern Ohio Electric Co. v. CommissionerUnited States Tax Court · 1956
- Commissioner of Internal Revenue v. Fifth Avenue Coach Lines, Inc., Fifth Avenue Coach Lines, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
2 more not listed; retrieve them via the Exa API.