October Mr. M. A. Browning, Ogden, Utah. Dear Mr. 4, 1940 Browning: We have the following information to report in reply to your memorandum dated September 23, 1940 relative to the Utah Idaho Central Railroad Company bonds now held in the Bar B Company. We have a letter signed by the Commissioner of Internal Revenue, Guy T. Helvering, stating that the transactions arising through the exchange of Utah Idaho Central Railroad Company bonds for stock and debentures of the new corporation will result in loss or gain to its bondholders who make the exchange. The only qualification in this written opinion is that a check by a revenue agent might disclose additionel facts which would nulify the opinion. This we do not feel will happen. The Railroad basis of bonds Company in the face $90,297.72 upon the Browning Company. This period, carries through value of the bonds bond so all worth $34,765.00. that basis, to the exchanged of these This of the Utah Idaho Central amount of $81,800.00 had a books of the J. M. & M. 58, as well as the Bar B Company. was bonds results holding The market $42.50 for for purposes tax in a loss each $100.00 are of $55,532.72. The Bar B Company, not being a personal holding company, is entitled to take this full loss during the year 1940 as an offset against any of its normal income. If this loss is not offset by gains during the current year you will be allowed..to carry it forward for two succeeding years, if the present law is not changed. regarding this If any further transaction, please Very truly information is call upon us. yours, required