Legal Opinion

Starr v. Commissioner

United States Tax Court

Decided June 29, 1966No. Docket No. 1104-63Published

Petitioner, on April 9, 1958, ordered through his broker K, at a price above par, $ 9 million face amount of U.S. Treasury 2 3/8-percent bonds due June 15, 1958. Bondholders had the privilege of exchanging these bonds for a new issue of 2 5/8-percent bonds due in 1965. Petitioner did not put up cash for margin or apply for a loan. K ordered bonds for petitioner and others from G, a New York broker.

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Petitioner, on April 9, 1958, ordered through his broker K, at a price above par, $ 9 million face amount of U.S. Treasury 2 3/8-percent bonds due June 15, 1958. Bondholders had the privilege of exchanging these bonds for a new issue of 2 5/8-percent bonds due in 1965. Petitioner did not put up cash for margin or apply for a loan. K ordered bonds for petitioner and others from G, a New York broker. G acquired the bonds and sold them at cost to P under a repurchase agreement permitting either party to reverse the sale. P collected the interest and exchanged the maturing bonds for the new…

1Opinion of the Court

Max Starr and Doris L. Starr, Petitioners, v. Commissioner of Internal Revenue, Respondent

Starr v. Commissioner

Docket No. 1104-63

United States Tax Court

46 T.C. 450; 1966 U.S. Tax Ct. LEXIS 80;

June 29, 1966, Filed

Decision will be entered under Rule 50.

Petitioner, on April 9, 1958, ordered through his broker K, at a price above par, $ 9 million face amount of U.S. Treasury 2 3/8-percent bonds due June 15, 1958. Bondholders had the privilege of exchanging these bonds for a new issue of 2 5/8-percent bonds due in 1965. Petitioner did not put up cash for margin or apply for a loan. K ordered bonds…

2Cases cited7 opinions

  1. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  2. Maysteel Products, Inc. v. CommissionerUnited States Tax Court · 1960
  3. Maysteel Products, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
  4. Industrial Research Products, Inc. v. CommissionerUnited States Tax Court · 1963
  5. Herbert Humphreys and Wilda Humphreys, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1962

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