Ades v. Commissioner
United States Tax Court
A partnership and certain individuals purchased convertible and callable bonds at a premium. Before amortizing the part of that premium not attributable to the conversion feature, they converted the bonds into common stock. Held, the unamortized part of such bond premium at the date of conversion is not an allowable deduction in the year of conversion.
1Opinion of the Court
Albert J. and Sylvia Ades, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Ades v. Commissioner
Docket Nos. 79388, 79389, 79390, 79391
United States Tax Court
38 T.C. 501; 1962 U.S. Tax Ct. LEXIS 109;
July 27, 1962, Filed
Decisions will be entered for the respondent.
A partnership and certain individuals purchased convertible and callable bonds at a premium. Before amortizing the part of that premium not attributable to the conversion feature, they converted the bonds into common stock. Held, the unamortized part of such bond premium at the date of conversion is not an…
2Cases cited17 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Crane v. CommissionerSupreme Court of the United States · 1947
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
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