Eastern Steamship Lines v. Commissioner
United States Board of Tax Appeals
1. A taxpayer in 1917 issued mortgage bonds for assets in reorganization and before the end of the year it purchased such bonds for less than their face amount. Held, no income. 2. Taxpayer's property was in 1917 requisitioned by the Government, and the compensation was more than cost. Taxpayer made no application to the Commissioner and gave no bond covering a replacement fund, as required by the regulations prescribed under the statute.
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1. A taxpayer in 1917 issued mortgage bonds for assets in reorganization and before the end of the year it purchased such bonds for less than their face amount. Held, no income. 2. Taxpayer's property was in 1917 requisitioned by the Government, and the compensation was more than cost. Taxpayer made no application to the Commissioner and gave no bond covering a replacement fund, as required by the regulations prescribed under the statute. Held, the excess was income and no deduction was allowable.
1Opinion of the Court
EASTERN STEAMSHIP LINES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Eastern Steamship Lines v. Commissioner
Docket No.24870.
United States Board of Tax Appeals
17 B.T.A. 787; 1929 BTA LEXIS 2245;
October 7, 1929, Promulgated
1. A taxpayer in 1917 issued mortgage bonds for assets in reorganization and before the end of the year it purchased such bonds for less than their face amount. Held, no income.
2. Taxpayer's property was in 1917 requisitioned by the Government, and the compensation was more than cost. Taxpayer made no application to the Commissioner and gave no bond…
2Cases cited12 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Rock Island, Arkansas & Louisiana Railroad v. United StatesSupreme Court of the United States · 1920
- Lucas v. AlexanderSupreme Court of the United States · 1929
- United States v. Supplee-Biddle Hardware Co.Supreme Court of the United States · 1924
- Appeal of New Orleans, Texas & Mexico Railway Co.United States Board of Tax Appeals · 1927
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