Legal Opinion
Estate of Gourielli v. Commissioner
Court of Appeals for the Second Circuit
Decided April 13, 1961No. Nos. 239,164, Dockets 26258, 26324PublishedCited by 4 opinions
1Opinion of the Court
FRIENDLY, Circuit Judge.
The issue in these two cases is whether, in a tax year, 1953, governed by §§ 23 (v) and 125, added to the 1939 Code by the Revenue Act of 1942, c. 619, § 126, 56 Stat. 798, 822, taxpayers who purchased bonds callable on 30 days’ notice may deduct, in addition to the excess of their basis over the redemption price at which the issuer could freely call all or any part of the issue, the excess of that price over a lower one at which the issuer could call bonds only out of specially defined funds. In both cases the Tax Court sustained determinations of the Commis.sioner…
2Cases cited10 opinions
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Takao Ozawa v. United StatesSupreme Court of the United States · 1922
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- Carl E. Weller and Emily I. Weller v. Commissioner of Internal Revenue, W. Stuart Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Commissioner v. KorellSupreme Court of the United States · 1950
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3Cited by4 opinions
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Evans v. DudleyCourt of Appeals for the Third Circuit · 1961
- Evans v. DudleyCourt of Appeals for the Third Circuit · 1961
- Estate of A. Gourielli, Deceased, the Hanover Bank, and Helena Gourielli, Surviving Wife v. Commissioner of Internal Revenue, Jacob A. And Bertha L. Goldfarb v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961