GENERAL GAS & ELECTRIC CORP.
v.
COMMISSIONER OF INTERNAL REVENUE
GENERAL GAS & ELECTRIC CORP.
COMMISSIONER OF INTERNAL REVENUE
306 U.S. 530
Supreme Court of the United States (1939)
Caution
Also reported at: 83 L. Ed. 964 · 59 S. Ct. 638 · SCDB 1938-070 · 1939 U.S. LEXIS 1165
Cited by 4 cases
Opinion of the Court
Mr. Justice Huberts delivered the opinion of the Court.
These are companion cases to Nos. 486 and 487, ante, p. 522, and involve the same question. The Circuit Court pf Appeals held that conveyances by subsidiaries to the taxpayer, consummated under the Act pf April 29, 1874, did not constitute mergers so as to authorize the taxpayer to take a deduction for unamortized bond discount and expense in ''respect of bonds issued by the subsidiaries prior to the conveyance.
For reasons given in Nos. 486 and 487 the judgments must be
Reversed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Hughes Tool Co. v. Commissioner OF Internal Revenue (two cases), 147 F.2d 967 (5th Cir. 1945)…the taxpayer of the covenant occurred after May 1, 1936, and was therefore not available. The cases of Helveriug v. Metropolitan Edison Co., 306 U.S. 522, 59 S.Ct. 634, 83 L.Ed. 957, and General Gas and Elec. Co. v. Commissioner of Internal Revenue, 306 U.S. 530, 59 S.Ct. 638, 83 L.Ed. 964, were distinguished, and no credit was allowed. We find in the provisions of the Revenue Act of 1936, 49 Stats. 1648, a broad policy to discourage by heavy multiple taxation both holding corporations and the non-distribu…