Scott Paper Co. v. Commissioner
United States Tax Court
Scott issued debentures which were convertible into shares of common stock. Interest on the debentures was paid twice yearly, on Mar. 1 and Sept. 1. Scott, a calendar year, accrual method taxpayer, annually deducted interest pursuant to sec. 163, I.R.C. 1954, in an amount equal to the sum of (1) interest accrued from Jan. 1 to Dec. 31 on debentures which were not converted during that taxable year; and (2) interest accrued from Jan. 1 to the date of conversion on debentures…
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Scott issued debentures which were convertible into shares of common stock. Interest on the debentures was paid twice yearly, on Mar. 1 and Sept. 1. Scott, a calendar year, accrual method taxpayer, annually deducted interest pursuant to sec. 163, I.R.C. 1954, in an amount equal to the sum of (1) interest accrued from Jan. 1 to Dec. 31 on debentures which were not converted during that taxable year; and (2) interest accrued from Jan. 1 to the date of conversion on debentures which were converted during that taxable year. Respondent disallowed that part of the claimed interest deduction which…
1Opinion of the Court
Scott Paper Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Scott Paper Co. v. Commissioner
Docket Nos. 1775-73, 2897-74
United States Tax Court
74 T.C. 137; 1980 U.S. Tax Ct. LEXIS 143; 74 T.C. No. 14;
April 28, 1980, Filed
Decisions will be entered under Rule 155.
Scott issued debentures which were convertible into shares of common stock. Interest on the debentures was paid twice yearly, on Mar. 1 and Sept. 1. Scott, a calendar year, accrual method taxpayer, annually deducted interest pursuant to sec. 163, I.R.C. 1954, in an amount equal to the sum of (1) interest accrued from…
2Cases cited39 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- United States v. AndersonSupreme Court of the United States · 1926
- Higgins v. SmithSupreme Court of the United States · 1940
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
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