Legal Opinion
United States v. Midland-Ross Corp.
Supreme Court of the United States
Decided May 3, 1965No. 628PublishedCited by 87 opinions
1Opinion of the CourtJustice Brennan
delivered, the opinion of the Court.
The question for decision is whether, under the Internal Revenue Code of 1939, certain gains realized by the taxpayer are taxable as capital gains or as ordinary income. The taxpayer bought noninterest-bearing promissory notes from the issuers at prices discounted below the face amounts. With one exception, each of the notes was held for more than six months, and, before maturity and in the year of purchase, was sold for less than its face amount but more than its issue price. It is conceded that the gain in each case was the economic equivalent of interest…
2Cases cited36 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
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3Cited by87 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- T. J. Starker v. United StatesCourt of Appeals for the Ninth Circuit · 1979
- Arkansas Best Corp. v. CommissionerSupreme Court of the United States · 1988
- United States v. Ada Belle Winthrop, Individually and as Under the Will of Guy L. Winthrop, DeceasedCourt of Appeals for the Fifth Circuit · 1969
- Chock Full O' Nuts Corporation v. United StatesCourt of Appeals for the Second Circuit · 1971
82 more not listed; retrieve them via the Exa API.