District Bond Co. v. Commissioner
United States Tax Court
Amounts received by the holder of municipal improvement bonds, designated penalties for the debtor's failure to pay installments of principal or interest at maturity, held not to constitute "interest" within the tax-exempting provision of section 22 (b) (4) of the Revenue Act of 1938; held, further, a bonus or premium paid upon the redemption of bonds before maturity does not constitute tax-exempt interest.
1Opinion of the Court
OPINION.
ARundeul, Judge:
The Commissioner' determined deficiencies in income tax for the years 1938 and 1939 in the respective amounts of $5,737.38 and $61.06. Petitioner disputes the correctness of only a portion of the deficiencies, claiming that amounts received as delinquency penalties and as premiums on the retirement of bonds were in reality tax-exempt interest upon the obligations of a state or its political subdivisions. The facts are stipulated.
Petitioner, a California corporation, filed its returns for 1938 and 1939 with the collector for the sixth district of California. During…
2Cases cited4 opinions
- Willcutts v. BunnSupreme Court of the United States · 1931
- Meilink v. Unemployment Reserves Comm'n of Cal.Supreme Court of the United States · 1942
- Meyer v. City and County of San FranciscoCalifornia Supreme Court · 1907
- Agudo v. County of MontereyCalifornia Supreme Court · 1939
3Cited by19 opinions
- Shattuck v. CommissionerUnited States Tax Court · 1955
- Intercounty Operating Corp. v. CommissionerUnited States Tax Court · 1944
- Leavin v. CommissionerUnited States Tax Court · 1962
- Bolnick v. CommissionerUnited States Tax Court · 1965
- Sharp v. CommissionerUnited States Tax Court · 1980
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