GENERAL GAS & ELECTRIC CORP. v. COMMISSIONER OF INT. REV.

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United States Supreme Court

GENERAL GAS & ELECTRIC CORP. v. COMMISSIONER OF INT. REV., (1939)

No. 492

Argued: March 10, 1939    Decided: April 3, 1939

Miss Helen R. Carloss, Sp. Asst. to Atty. Gen., for Commissioner of Internal Revenue.

Mr. Maurice Bower Saul, of Philadelphia, Pa., for General Gas & Electric Co.

Mr. Justice ROBERTS delivered the opinion of the Court.

These are companion cases to Nos. 486 and 487 Helvering v. Metropolitan Edison Co., 306 U.S. 522 , 59 S.Ct. 634, 83 L.Ed. --, and involve the same question. The Circuit Court of Appeals held that conveyances by subsidiaries to the taxpayer, consummated under the Act of April 29, 1874 (15 P.S.Pa. 595), did not constitute mergers so as to authorize the taxpayer to take a deduction for unamortized bond discount and expense in respect of bonds issued by the subsidiaries prior to the conveyance.

For reasons given in Nos. 486 and 487 the judgments must be reversed. So ordered

Reversed.

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