Legal Opinion
Pattiz v. United States
United States Court of Claims
Decided January 11, 1963No. Nos. 219-61, 244-61, 245-61, 282-61 to 287-61PublishedCited by 12 opinions
1Opinion of the Court
WHITAKER, Judge.
The issue presented in these cases is whether the difference between the purchase price of registered notes and the price at which the payor redeemed them is ordinary income or a capital gain.
Plaintiffs rely on section 117(f) of the Internal Revenue Code of 1939, as amended, which provides:
“For the purposes of this chapter, amounts received by the holder upon the retirement of bonds, debentures, notes, or certificates or other evidences of indebtednesses issued by any corporation (including those issued by a government or political subdivision thereof), with interest coupons…
2Cases cited10 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Commissioner of Internal Revenue v. CaulkinsCourt of Appeals for the Sixth Circuit · 1944
- Commissioner of Internal Revenue v. J. I. Morgan and Frances MorganCourt of Appeals for the Ninth Circuit · 1959
- Watson v. CommissionerUnited States Board of Tax Appeals · 1932
5 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- United States v. Midland-Ross Corp.Supreme Court of the United States · 1965
- The Prudential Insurance Company of America v. The United StatesUnited States Court of Claims · 1963
- Union Pacific Railroad v. United StatesUnited States Court of Claims · 1975
- Bolnick v. CommissionerUnited States Tax Court · 1965
- National Life and Accident Insurance Co. v. United StatesDistrict Court, E.D. Tennessee · 1965
7 more not listed; retrieve them via the Exa API.