Estate of Noel v. Commissioner
United States Tax Court
Decedent owned subordinated corporate debenture bonds which had been issued at a discount and which became due on Jan. 1, 1956. Decedent died on June 20, 1956, without receiving any payments on the bonds. In 1957 decedent's estate transferred the bonds to a creditor of decedent and received a credit against the indebtedness of the full face value of the matured bonds.
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Decedent owned subordinated corporate debenture bonds which had been issued at a discount and which became due on Jan. 1, 1956. Decedent died on June 20, 1956, without receiving any payments on the bonds. In 1957 decedent's estate transferred the bonds to a creditor of decedent and received a credit against the indebtedness of the full face value of the matured bonds. Held, the increment in value (discount) of the bonds is taxable as ordinary income to decedent's estate, as income in respect of a decedent under sec. 691, I.R.C. 1954, in the year 1957; the increment was not taxable to…
1Opinion of the Court
Estate of Marshal L. Noel, Ruth M. Noel, Executrix, and William H. Frantz, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Noel v. Commissioner
Docket No. 645-66
United States Tax Court
50 T.C. 702; 1968 U.S. Tax Ct. LEXIS 92;
July 31, 1968, Filed
Decision will be entered for the respondent.
Decedent owned subordinated corporate debenture bonds which had been issued at a discount and which became due on Jan. 1, 1956. Decedent died on June 20, 1956, without receiving any payments on the bonds. In 1957 decedent's estate transferred the bonds to a creditor of decedent and…
2Cases cited5 opinions
- United States v. Midland-Ross Corp.Supreme Court of the United States · 1965
- Gullett v. CommissionerUnited States Board of Tax Appeals · 1935
- Jacobs v. CommissionerUnited States Board of Tax Appeals · 1931
- Evelyn Z. Levin v. United StatesCourt of Appeals for the First Circuit · 1967
- Estate of Noel v. CommissionerUnited States Tax Court · 1968