Legal Opinion

Agency of Canadian Car & Foundry Co. v. Commissioner

United States Tax Court

Decided October 3, 1962No. Docket Nos. 83825, 83826Published

1. Payments on Mixed Claims Commission Award -- German Bonds to Fund Payments. -- Held, bonds issued in 1953 by the Federal Republic of Germany to the Government of the United States of America, payable serially each year beginning in 1953 and ending in 1978, are not capital assets in the hands of the taxpayer within the provisions of section 1232(a), 1954 Internal Revenue Code, notwithstanding the fact that the net amount of the funds derived from the payment of the bonds…

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1. Payments on Mixed Claims Commission Award -- German Bonds to Fund Payments. -- Held, bonds issued in 1953 by the Federal Republic of Germany to the Government of the United States of America, payable serially each year beginning in 1953 and ending in 1978, are not capital assets in the hands of the taxpayer within the provisions of section 1232(a), 1954 Internal Revenue Code, notwithstanding the fact that the net amount of the funds derived from the payment of the bonds on maturity are paid over ratably to holders of awards of the Mixed Claims Commission, United States and Germany, by the…

1Opinion of the Court

Agency of Canadian Car and Foundry Company, Limited, Petitioner, v. Commissioner of Internal Revenue, Respondent

Agency of Canadian Car & Foundry Co. v. Commissioner

Docket Nos. 83825, 83826

United States Tax Court

39 T.C. 15; 1962 U.S. Tax Ct. LEXIS 59;

October 3, 1962, Filed

Decisions will be entered for the respondent.

1. Payments on Mixed Claims Commission Award -- German Bonds to Fund Payments. -- Held, bonds issued in 1953 by the Federal Republic of Germany to the Government of the United States of America, payable serially each year beginning in 1953 and ending in 1978, are not capital assets…

2Cases cited11 opinions

  1. Fairbanks v. United StatesSupreme Court of the United States · 1939
  2. Bingham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1939
  3. H. E. Harman Coal Corp. v. CommissionerUnited States Tax Court · 1951
  4. Commissioner of Internal Revenue v. H. E. Harman Coal CorpCourt of Appeals for the Fourth Circuit · 1952
  5. Richard T. Graham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962

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