Congress Square Hotel Co. v. Commissioner
United States Tax Court
Petitioner entered into a contract with certain underwriters to sell to them a new issue of bonds. Pursuant thereto payment was made by check and the bonds delivered to the underwriters. The check, together with additional cash and the old bonds then in petitioner's treasury, was used to discharge the mortgage and retire the old bonds.
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Petitioner entered into a contract with certain underwriters to sell to them a new issue of bonds. Pursuant thereto payment was made by check and the bonds delivered to the underwriters. The check, together with additional cash and the old bonds then in petitioner's treasury, was used to discharge the mortgage and retire the old bonds. The underwriters agreed to offer a like amount of new bonds to old bondholders at the call price of the old bonds for a limited time, thereafter to others at a specified higher price. The old bondholders surrendered their bonds to a designated bank acting as…
1Opinion of the Court
OPINION.
Arnold, Judge:
This case involves corporation income, declared value excess profits, and excess profits taxes for the calendar year 1941 in the aggregate amount of $80,441.65. Certain adius tments were made by respondent which are not here contested. A st ipulation of facts containing certain exhibits was filed and we incorporate it herein by reference. The case hinges on whether the unamorti; ed discount and expenses of old bonds are deductible in the taxable i ear, as contended by the petitioner, or should be amortized over tho life of the new bonds, as determined by respondent.
Petiti…
2Cases cited1 opinion
- Great Western Power Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
3Cited by6 opinions
- Bridgeport Hydraulic Co. v. CommissionerUnited States Tax Court · 1954
- South Carolina Continental Telephone Co. v. CommissionerUnited States Tax Court · 1948
- South Carolina Continental Tel. Co. v. CommissionerUnited States Tax Court · 1948
- Bridgeport Hydraulic Co. v. CommissionerUnited States Tax Court · 1954
- Congress Square Hotel Co. v. CommissionerUnited States Tax Court · 1945
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