Sun Pipe Line Co. v. Commissioner

42 B.T.A. 1413, 1940 BTA LEXIS 868
CourtUnited States Board of Tax Appeals
DecidedNovember 29, 1940
DocketDocket No. 98764.
StatusPublished
Cited by6 cases

This text of 42 B.T.A. 1413 (Sun Pipe Line Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sun Pipe Line Co. v. Commissioner, 42 B.T.A. 1413, 1940 BTA LEXIS 868 (bta 1940).

Opinion

[1416]*1416OPINION.

Disney:

Stated tersely, the problem for solution here is whether section 351 (b) (2) (B) of the Revenue Act of 1936, as amended by section 355 (b) of the Revenue Act of 1937,1 by the phrase “indebtedness incurred prior to January 1, 1934”, was intended to cover indebtedness which existed prior to that date in the form of debentures and was retired after the crucial date, new bonds being issued for cash and the proceeds being used to retire the old debentures. In a word, the facts before us are that 5 percent bonds were issued in 1930 to certain parties and were retired in 1934 with the proceeds of a 3½ percent bond issue sold to parties other than those holding the issue of 1930, though the trustee was the same for both issues. In 1937 it redeemed the 3½ percent bonds and deducted the amount of such redemption from its undistributed adjusted net income, acting under the provisions of section 351 (b) (2) (B) of the Revenue Act of 1936, as amended by section 355 (b) of the Revenue Act of 1937. The Commissioner denied such deduction.

The question is one of first impression. The petitioner cites no case specifically considering the point here raised, and the respondent [1417]*1417agrees that there is no authority exactly in point, though he adduces and relies upon certain cases as embodying the principle properly to be applied here.

After much study of this vexing problem, we have concluded that Congress did not intend to deny credit for payments upon indebtedness which represents an actual, though not a technical, continuance of indebtedness existing prior to January 1, 1934. The statute originated in section 351 of the Revenue Act of 1934, where the language used was identical with that in the 193G Act. Of this statute, the Senate Finance Committee report said:

* * * Considerable hardship has been avoided by permitting the deduction from the adjusted net income of a reasonable amount used or set aside to retire indebtedness incurred prior to January 1, 1934. This will substantially and properly relieve personally owned corporations which have outstanding bonds or other indebtedness that must be met from current earnings before distributions can be made.

The requirement spoken of by the committee, “that must be met from current earnings before distributions can be made”, seems to apply alike to “bonds or other indebtedness” already issued on the effective date, and those with which the original issue is supplanted, but where the economic position of the taxpayer is not altered. We think that no distinction was intended between a corporation which after the date set, changes the form of its obligation, even changes the obligee, but remains equally obligated, and one which merely remains bound by the original obligation. True, the statutory date must be given meaning and effect, but we think this is reasonably done and Congressional intent accomplished by denying credit to indebtedness which is new in an economic sense to the taxpayer, i. e., does not merely take the place of indebtedness existing prior to the effective date. This seems to be the thought behind the language of the Ways and Means Committee Report on the Revenue Act of 1937 when, denying a recommendation that the credit for retirement of indebtedness provision be repealed, it said:

* * * -while recognizing the reasons which impelled the joint committee to make this recommendation, your committee feels, from- further study of .the question, that the denial of this deduction would cause hardship in numerous eases where, due to the particular circumstances of the corporation, a dividend distribution can not be made because of a necessity for legal reasons of using the earnings and profits to discharge the debts. Moreover, any loss of revenue caused by the continued allowance of this deduction can not increase, since indebtedness incurred after 1933 can not be used as a basis for the deduction. No corporation cm, be formed for the purpose of taking advantage of this deduction. Furthermore, it is inevitable that the revenue loss must decrease as pre-1934 debts are retired. * * * [Italics supplied.]

The Committee seemed to think that if “pre-1934 debts are retired” and new corporations for taking advantage of the deduction pre[1418]*1418vented, justice will be subserved. The intent in our opinion was to prevent further incorporating of the pocketbook, but not to affect those incorporations already existing. Here the incorporation of pocketbook was done when the corporation was formed and the original bonds were issued, not when the state of indebtedness was continued in a slightly different form. In Commissioner v. Tennessee Co., 111 Fed. (2d) 678, the court considered the question whether “indebtedness” included indebtedness contingent at the effective date set by the act. After pointing out that the word “indebtedness” has both a strict and a broad meaning, the court came to the conclusion that a broad implication was required by the act and stated that “the operation of the statute is ‘cushioned’ so as to make it prospective in case of debt retirement payments”, and though the court was of the opinion that the kind of debt in the case considered was one “most calculated to accomplish avoidance”, nevertheless upheld the deduction, saying: “So we must await the happy day when pre-1934 indebt-ednesses are finally extinguished.”

The Revenue Act of 1936 provides, hi section 351 (b) (3) (B), that credit shall be allowed for certain contributions or gifts:

* * * including, in tlie case of a corporation organized prior to January 1,1936, to take over the assets and liabilities of the estate of a decedent, amounts paid in liquidation of any liability of the corporation based on the liability of the decedent to make any such contribution or gift, to the extent such liability of the decedent existed prior to January 1, 1934; * * *

The case of such corporation was new in the act. Commenting on the inclusion thereof, the Report of the Conference Committee says:

Contributions or gifts to charitable organizations pledged by an individual who died prior to January 1, 193'6, and assumed by a corporation organized to take over the assets and liabilities of the estate of such decedent after that date are allowed as a deduction in computing the adjusted net income for the purposes of this tax. This deduction seems meritorious, for the liabilities assumed by the corporation are with respect to gifts going to charitable organizations and were actually incurred prior to January 1, 1936, but due to the delay in the organization of the corporation were not actually incurred by the corporation as such until after that date.

It would seem from such language that there was Congressional intent not to exclude from credit, where the debt was not “actually incurred” after the effective date, but represented indebtedness existing prior thereto; and that such thought applies equally in case of new bonds to take up those prior to the date involved.

The question as to what constitutes the incurrence of indebtedness has received the attention of the courts in connection with municipal bond issues in excess of constitutional or statutory limits. Though there are decisions to the contrary, the weight of authority is that a [1419]

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Sun Pipe Line Co. v. Commissioner
42 B.T.A. 1413 (Board of Tax Appeals, 1940)

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Bluebook (online)
42 B.T.A. 1413, 1940 BTA LEXIS 868, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sun-pipe-line-co-v-commissioner-bta-1940.