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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.

2 Citing cases

  1. St. Louis-San Francisco R. v. United States

    470 F.2d 523 (Fed. Cir. 1972)   Cited 4 times

    We agree. This issue is governed by our decision in Chicago, Milwaukee, St. Paul and Pacific R. R. v. United States, 404 F.2d 960, 186 Ct.Cl. 250 (1968). In that case, we held that issuance expense would be treated as would discount, and this being so, there could be no carryover of debt discount or issuance expense if the maturity value of the new bonds is less than the amount that was received when the old securities were issued.

  2. St. Louis-San Francisco Ry. v. United States

    195 Ct. Cl. 343 (Fed. Cir. 1971)   Cited 8 times
    In St. Louis-San Francisco Railway Co. v. United States, 444 F.2d 1102, 95 Ct.Cl. 343, 350-351 (1971), cert. denied 404 U.S. 1017, 92 S.Ct. 678, 30 L.Ed.2d 665 (1972), this court recently rejected an attempt by a taxpayer to recharacterize the tax consequences of an exchange of income debentures and no-par common stock for preferred stock having a par value equal to the face value of the debentures.

    In an analogous situation, we ignored the issuance of preferred stock in determining whether there was a carry-over of debt discount and compared only the maturity value of new bonds and cash with the face value of the old bonds given up in the exchange. Chicago, Milwaukee, St. Paul and Pacific R.R. v. United States, 186 Ct.Cl. 250, 263, 404 F.2d 960, 967 (1968). Common stock is not a fixed debt obligation, and the plaintiff made no definite obligation for the future by issuing those shares.