O'Brien v. Commissioner

OPINION.

Raum, Judge:

During 1944 petitioner received an aggregate of $26,144.77 from Guardian Depositors Corporation in connection with the Settlement Fund Certificate to which she had succeeded as the sole residuary legatee of the estate of her deceased husband. Of that amount, $8,554.25 was denominated as “interest”; the remaining $17,-590.52 represents so-called principal. The question for decision is whether the $26,144.77, or any of its components, represents taxable income, reportable by petitioner. We shall deal separately with the items of principal and interest.

1. As to principal of…