Helvering v. Union Pacific Railroad Co., 293 U.S. 282 (1934)

Helvering v. Union Pacific Railroad Co.


No. 51


Argued November 7, 1934
Decided December 3, 1934
293 U.S. 282

CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE SECOND CIRCUIT

Syllabus

1. A corporation which sold an issue of bonds at a discount and paid commissions for marketing them, and which keeps its accounts and makes its returns on the accrual basis, may amortize the commissions as well as the discount over the life of the bonds, and the amount so allocated to each year may be deducted from gross income as a loss or expense of that year. P. 284.

2. So held where the commissions had been paid or allowed before the year 1913. Old Colony R. Co. v. Commissioner, 284 U.S. 552, distinguished. P. 287.

69 F.2d 67 affirmed.

Certiorari to review the reversal of a decision of the Board of Tax Appeals, 26 B.T.A. 1126, upholding in part a deficiency assessment made by the Commissioner.