COMMISSIONER OF INTERNAL REV. v. GREAT WESTERN P. CO.

No. 402.

79 F.2d 94 (1935)

COMMISSIONER OF INTERNAL REVENUE v. GREAT WESTERN POWER CO. OF CALIFORNIA.

Circuit Court of Appeals, Second Circuit.

July 22, 1935.


Attorney(s) appearing for the Case

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and A. F. Prescott, Sp. Assts. to Atty. Gen., for petitioner.

Thomas R. Dempsey and A. Calder Mackay, both of Los Angeles, Cal., for respondent.

Before L. HAND, AUGUSTUS N. HAND, and CHASE, Circuit Judges.


CHASE, Circuit Judge.

During the taxable period the respondent was a public utility corporation of the state of California subject to the jurisdiction of the California State Railroad Commission. It kept its books on the accrual basis in accordance with the orders of said commission, and filed its income tax return on the accrual basis. The Board held that it was entitled to deduct as a loss the entire unamortized discount, expenses of issuance, premiums paid, and...

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