United States Supreme Court Cases & Opinions

U.S. Supreme Court

Sioux City & Pacific R. Co. v. United States, 110 U.S. 205 (1884)

Sioux City and Pacific Railroad Company v. United States

Submitted December 18, 1883

Decided January 21, 1884

110 U.S. 205

Syllabus

Under the Act of July 1, 1882, 12 Stat. 492-493, and the acts in addition to it, plaintiff in error received from defendant in error subsidy bonds, which were made by statute a lien upon its road. Held that in a suit to collect an internal revenue tax on the undivided net earnings of the road, carried to a fund or to construction account, the plaintiff was not entitled to have the interest upon these bonds deducted from its net earnings before settling the amount to be subject to the tax; but that the amount of that interest, if earned and carried to a fund or charged to construction, was taxable.

Suit to recover an internal revenue tax on the undivided net earnings of the plaintiff's railroad. Defense that the company was not subject to the tax to the extent of the interest on the subsidy bonds issued to it under the Act of July 1, 1862, 12 Stat. 489, c. 120.