Great Western Power Co. v. Commissioner, 297 U.S. 543 (1936)

Great Western Power Company of California v.


Commissioner of Internal Revenue
No. 525


Argued March 5, 1936
Decided March 16, 1936
297 U.S. 543

CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE SECOND CIRCUIT

Syllabus

Under § 234(a), Revenue Act of 1924, and Treasury Regulations 65, Art. 545, § 3, where bonds of a corporation, sold at a discount, are retired by exchanging for them bond of another issue and paying a premium, the unamortized discount and expense of issuance allocable to the retired bonds, and the premium paid and expense incurred in the exchange, are part of the cost of obtaining the loan and, for the purpose of deduction in income accounting, should be amortized over the term of the bonds delivered in the exchange. P. 546.

79 F.2d 94 affirmed.

Certiorari, 296 U.S. 568, to review a judgment reversing a decision of the Board of Tax Appeals, 30 B.T.A. .503, which overruled the Commissioner of Internal Revenue in respect of the disallowance of deductions in the Power Company’s income tax return.