Bangor and Aroostook Railroad Co. v. Commissioner
United States Court of Appeals for the First Circuit
193 F.2d 827 (1951)
Facts
Bangor and Aroostook Railroad Company (Bangor) (plaintiff) purchased and cancelled some of its bonds, which produced a bond profit in 1942. Bangor elected to exclude the bond profit from its 1942 tax return under Internal Revenue Code §§ 108 and 1017. However, Bangor included the bond profit in its calculations to reduce its excess profits tax on its 1943 tax return by including it as invested capital under §§ 714 and 718. The commissioner of the Internal Revenue Service (defendant) assessed a deficiency through disallowance of the inclusion of the bond profit in the calculation of excess-profits tax. Bangor appealed the assessment to the United States Tax Court, which affirmed the assessment. Bangor appealed the decision to the United States Court of Appeals for the First Circuit.
Rule of Law
Issue
Holding and Reasoning (Magruder, C.J.)
What to do next…
Here's why 711,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 44,600 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
