Durham Tel. Co. v. Commissioner
United States Tax Court
Held, that the transactions here involved between petitioner and the holder of all its outstanding old bonds did not constitute purchase and sale transactions, but an exchange or substitution of new bonds for old as evidence of a continuing indebtedness between the same parties.
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Held, that the transactions here involved between petitioner and the holder of all its outstanding old bonds did not constitute purchase and sale transactions, but an exchange or substitution of new bonds for old as evidence of a continuing indebtedness between the same parties. Further, held, that the amount paid for premium and unamortized discount and expense upon retirement of the old bonds in 1941 is not deductible in full in that year, but should be amortized over the life of the new bonds issued in exchange for the old. South Carolina Continental Telephone Company, 10 T.C. 164…
1Opinion of the Court
Durham Telephone Company v. Commissioner.
Durham Tel. Co. v. Commissioner
Docket No. 10331.
United States Tax Court
1948 Tax Ct. Memo LEXIS 264; 7 T.C.M. (CCH) 49; T.C.M. (RIA) 48010;
January 28, 1948
Held, that the transactions here involved between petitioner and the holder of all its outstanding old bonds did not constitute purchase and sale transactions, but an exchange or substitution of new bonds for old as evidence of a continuing indebtedness between the same parties. Further, held, that the amount paid for premium and unamortized discount and expense upon retirement of the old bonds in…
2Cases cited1 opinion
- South Carolina Continental Telephone Co. v. CommissionerUnited States Tax Court · 1948