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Chicago, Milwaukee, St. Paul v. U.S.

404 F.2d 960 (Fed. Cir. 1968)
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Chicago, Milwaukee, St. Paul v. U.S.

1 Citing case

  1. Union Pac. R. Co., Inc. v. United States

    524 F.2d 1343 (Fed. Cir. 1975)   Cited 15 times
    In Union Pacific we concluded that plaintiff was not entitled to deduct payroll taxes in the earlier year because "all events" fixing liability for the tax had not occurred in this prior year. It must be reemphasized that we used the "all events" test to reach this result.

    The decision has been applied in this court to bond issuance costs generally. Chicago, Milwaukee R. Co. v. United States, 404 F.2d 960, 967, 186 Ct.Cl. 250, 262 (1968). The Supreme Court in its opinion said that discount and expense were both "factors in arriving at the actual amount of interest paid for the use of capital procured by a bond issue" which "must be added to the aggregate coupon payments in order to arrive at the total interest paid."