Opinion

Great W. Power Co. v. Commissioner

  • 30 B.T.A. 503
  • 1934 BTA LEXIS 1317
Court
United States Board of Tax Appeals
Filed
Apr 26, 1934
Status
Published
Author
Sternhagen
On the bench
Sternhagen, Fossan
Cited by
2 cases

The opinion

Sternhagen,

dissenting: In my opinion, the proportionate un-amortized discount and costs of the General Lien 8’s, dealt with in the second point, should not be deducted in 1924 when they were converted, as originally provided, into 7’s; but should be spread over the term of the Y’s. I agree with Judge Mack’s dissenting opinion in San Joaquin Light & Power Co. v. McLaughlin, 65 Fed. (2d) 677, that the obligation of the Y’s should be regarded as a continuation pro tanto of the indebtedness of the original issue.

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