British Yukon Railway Co. v. The Queen, 77 DTC 5176,  CTC 256 (FCTD)
Regulation 406 deals only with railway corporations operating between Canadian provinces and accordingly did not apply to the allocation of income from a railroad that ran through Alaska, the Yukon and B.C. The method used by the taxpayer, which was to apply paragraph 1.863-4 of the Regulations to the Internal Revenue Code, was found to be in accord with ordinary business and commercial principles.
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