Consolidated Gas Co. v. Commissioner
United States Board of Tax Appeals
1. If a corporation purchases and retires any of its bonds at a price less than the issuing price, the excess of the issuing price over the purchase price is gain or income for the taxable year. 2. Where a taxpayer keeping its books on an accrual basis, acquired certain of its own bonds with interest coupons attached thereto, the excess of the face value of the coupons over the amount paid for them is taxable as income.
1Opinion of the Court
OPINION.
Murdock :
The Commissioner determined deficiencies of $289,-351.86 and $53,827.91 in the petitioner’s income and profits taxes for the calendar years 1921 and 1922, respectively. The petitioner alleges that the Commissioner erroneously included in its income *902for the respective years the sums of $986,625 and $472,404.16, representing the difference between the prices at which it acquired and retired certain of its bonds, and interest coupons attached thereto, and the par value of such bonds and coupons.
The facts were stipulated, as follows:
The petitioner is a corporation of the…
2Cases cited3 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Cotton v. Territory of Hawaii Ex Rel. HollowaySupreme Court of the United States · 1908
3Cited by4 opinions
- Montana, W. & S. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Virginia Iron, Coal & Coke Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Consolidated Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Transylvania R. Co. v. CommissionerUnited States Board of Tax Appeals · 1937