GARLAND COAL & MINING CO. v. HELVERING

No. 6233.

75 F.2d 663 (1935)

GARLAND COAL & MINING CO. v. HELVERING, Commissioner of Internal Revenue.

United States Court of Appeals for the District of Columbia.

Decided January 14, 1935.


Attorney(s) appearing for the Case

William R. Spofford, of Philadelphia, Pa., for petitioner.

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key, Robert H. Jackson, William E. Davis, and Louise Foster, all of Washington, D. C., for respondent.

Before MARTIN, Chief Justice, and ROBB, VAN ORSDEL, HITZ, and GRONER, Associate Justices.


GRONER, Associate Justice.

Petitioner is a Delaware corporation. In 1926 it issued $175,000 of bonds secured by a mortgage upon its properties located in Arkansas and Oklahoma. The entire issue was sold at par. A part of the bonds were designated A and a part B bonds.

On January 1, 1928, $60,000 of A bonds and $100,000 of B bonds were outstanding. During that year petitioner "acquired $100,000 principal amount of B bonds by purchase at a cost of $47,039.80...

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