Goodstein v. Commissioner
United States Tax Court
1. Deductions -- Interest. -- Transaction whereby petitioner purported to purchase $ 10,000,000 face amount of United States Treasury notes, giving his note for all but $ 15,000 of the purchase price, held, lacking in substance and insufficient to create indebtedness.
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1. Deductions -- Interest. -- Transaction whereby petitioner purported to purchase $ 10,000,000 face amount of United States Treasury notes, giving his note for all but $ 15,000 of the purchase price, held, lacking in substance and insufficient to create indebtedness. Disallowance of claimed interest deductions approved. 2. Capital Gain -- Redemption of Debentures. -- Gain on redemption of debentures in registered form acquired at a discount and held for more than 6 months, held properly reported as long-term capital gain. George Peck Caulkins, 1 T. C. 656, affd. 144 F.2d 482, followed.
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax for the calendar years 1952 and 1953 in the respective amounts of $29,118.51 and $126,586.96. The petitioners allege that the respondent erred in disallowing deductions claimed for interest paid in those years in the respective amounts of $50,000 and $170,511.82, in connection with the purchase of United States Treasury notes, the interest on which is fully taxable. Alternatively, they allege that the respondent erred in failing to allow as a loss deduction for 1952 an amount of $14,722.02 paid in connection with the…
2Cases cited22 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
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3Cited by134 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
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- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Davis v. CommissionerUnited States Tax Court · 1976
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