St. Louis, Rocky Mountain & Pacific Co. v. Commissioner
United States Tax Court
Premium paid by petitioner to its bondholders upon the repurchase of its outstanding first mortgage bonds and interest paid to a trustee under bond indenture are deductions which must be allocated between income from mining operations and income from other activities in computing the 50 per cent of net income limitation on petitioner's coal depletion deduction under section 114 (b) (4), I. R. C. 1939.
1Opinion of the Court
St. Louis, Rocky Mountain and Pacific Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
St. Louis, Rocky Mountain & Pacific Co. v. Commissioner
Docket No. 57507
United States Tax Court
28 T.C. 28; 1957 U.S. Tax Ct. LEXIS 223;
April 15, 1957, Filed
Decision will be entered under Rule 50.
Premium paid by petitioner to its bondholders upon the repurchase of its outstanding first mortgage bonds and interest paid to a trustee under bond indenture are deductions which must be allocated between income from mining operations and income from other activities in computing the 50 per cent of…
2Cases cited4 opinions
- B. F. Goodrich Co. v. CommissionerUnited States Tax Court · 1943
- Guanacevi Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
- Sheridan-Wyoming Coal Co. v. HelveringCourt of Appeals for the D.C. Circuit · 1941
- St. Louis, Rocky Mountain & Pacific Co. v. CommissionerUnited States Tax Court · 1957