Watson v. Commissioner
United States Board of Tax Appeals
1. Where a statute is clear and unambiguous in its terms and provisions, resort should not be had to legislative history to determine the limits of its compass. 2. The words "sale or exchange" used in section 101(c)(2) of the Revenue Act of 1928, being ordinary words of well established meaning, are to be so interpreted in applying the section to any given transaction. 3. Payment of the amount specified in a bond, either at maturity or pursuant to an authorized call prior to…
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1. Where a statute is clear and unambiguous in its terms and provisions, resort should not be had to legislative history to determine the limits of its compass. 2. The words "sale or exchange" used in section 101(c)(2) of the Revenue Act of 1928, being ordinary words of well established meaning, are to be so interpreted in applying the section to any given transaction. 3. Payment of the amount specified in a bond, either at maturity or pursuant to an authorized call prior to maturity, is not a "sale or exchange" of such bond. It is merely the payment of an obligation according to its fixed…
1Opinion of the Court
JOHN H. WATSON, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Watson v. Commissioner
Docket No. 53414.
United States Board of Tax Appeals
27 B.T.A. 463; 1932 BTA LEXIS 1063;
December 29, 1932, Promulgated
1. Where a statute is clear and unambiguous in its terms and provisions, resort should not be had to legislative history to determine the limits of its compass.
2. The words "sale or exchange" used in section 101(c)(2) of the Revenue Act of 1928, being ordinary words of well established meaning, are to be so interpreted in applying the section to any given transaction.
3. Payment…
2Cases cited6 opinions
- Watson v. CommissionerUnited States Board of Tax Appeals · 1932
- Dahlinger v. CommissionerUnited States Board of Tax Appeals · 1930
- Leubuscher v. CommissionerUnited States Board of Tax Appeals · 1930
- Werner v. CommissionerUnited States Board of Tax Appeals · 1929
- Price v. CommissionerUnited States Board of Tax Appeals · 1928
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