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HELVERING v. UNION PACIFIC RAILROAD CO.

No. 51.

293 U.S. 282 (1934)

55 S.Ct. 165

79 L.Ed. 363

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. UNION PACIFIC RAILROAD CO.

Supreme Court of United States.

Decided December 3, 1934.

Attorney(s) appearing for the Case

Mr. H. Brian Holland, with whom Solicitor General Biggs, Assistant Attorney General Wideman, and Messrs. J. Louis Monarch and Morton K. Rothschild were on the brief, for petitioner.

Mr. Henry W. Clark for respondent.

MR. JUSTICE STONE delivered the opinion of the Court.

Prior to 1913 respondent, directly or through a subsidiary corporation, sold three issues of bonds, all maturing at dates subsequent to 1923. All were sold at a discount and petitioner paid or allowed to bankers an additional amount as commissions for marketing the bonds. The commissions and discounts, amortized over the periods from the dates of issue to maturity of the...

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