Virginia Iron, Coal & Coke Co. v. Commissioner
United States Board of Tax Appeals
Income derived by the petitioner from the purchase of its bonds is taxable in the year of such purchase, Garland Coal & Mining Co.,28 B.T.A. 348, followed, and the measure of income is the difference between the issuing and purchase price and not the difference between their March 1, 1913, value and the purchase price.
1Opinion of the Court
opinion.
Morris :
This proceeding is for the redetermination of deficiencies in income tax of $11,794.94, $14,913.92, and $16,967.68 for the calendar years 1922, 1923, and 1925, respectively.
Two questions are raised for our consideration; whether income arising from the purchase by a taxpayer of its own bonds is to be reported in the year in which the purchase is made or in the year when the bonds are canceled and retired, when purchase and cancellation do not occur in the same year, and whether the amount of the gain is the difference between the issuing price and the purchase price or the…
2Cases cited3 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Garland Coal & Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Consolidated Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1931
3Cited by4 opinions
- Montana, W. & S. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Tennessee Consol. Coal Co. v. CommissionerUnited States Tax Court · 1943
- Transylvania R. Co. v. CommissionerUnited States Board of Tax Appeals · 1937
- Virginia Iron, Coal & Coke Co. v. CommissionerUnited States Board of Tax Appeals · 1934