Leavin v. Commissioner
United States Tax Court
Petitioners purchased at a discount from the issuers certain debentures. The debentures provided for a 6-year maturity. The issuers were in the housebuilding business and intended to redeem the debentures as soon as the specific sections financed thereby were completed and sold. Petitioners herein knew of this intention. No debenture was outstanding for as long as 18 months. The debentures were redeemed at "face."
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Petitioners purchased at a discount from the issuers certain debentures. The debentures provided for a 6-year maturity. The issuers were in the housebuilding business and intended to redeem the debentures as soon as the specific sections financed thereby were completed and sold. Petitioners herein knew of this intention. No debenture was outstanding for as long as 18 months. The debentures were redeemed at "face." Held, petitioners realized ordinary income to the extent of the excess of the amounts realized on redemption over the amounts paid for the debentures.
1Opinion of the Court
V. David Leavin and Lillian Leavin, Petitioners, v. Commissioner of Internal Revenue, Respondent. Sol Davidson and Grace Davidson, Petitioners, v. Commissioner of Internal Revenue, Respondent
Leavin v. Commissioner
Docket Nos. 86531, 86532
United States Tax Court
37 T.C. 766; 1962 U.S. Tax Ct. LEXIS 206;
January 17, 1962, Filed
Decisions will be entered for the respondent.
Petitioners purchased at a discount from the issuers certain debentures. The debentures provided for a 6-year maturity. The issuers were in the housebuilding business and intended to redeem the debentures as soon as the specific…
2Cases cited12 opinions
- 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
- Caulkins v. CommissionerUnited States Tax Court · 1943
- Harry Rosen and Rose Rosen v. United StatesCourt of Appeals for the Third Circuit · 1961
- J. I. Morgan, Inc. v. CommissionerUnited States Tax Court · 1958
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