Corn Exchange Bank v. Commissioner
United States Board of Tax Appeals
Petitioner purchased bonds and securities of other corporations for resale and as investments. Through the use of recognized tables prepared for the purpose of determining the annual amortization of the discounts or premium on such bonds, petitioner determined the annual amount which, over the period between the date of purchase and the date of maturity, would amortize the difference between the purchase price and the face value of the bonds held.
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Petitioner purchased bonds and securities of other corporations for resale and as investments. Through the use of recognized tables prepared for the purpose of determining the annual amortization of the discounts or premium on such bonds, petitioner determined the annual amount which, over the period between the date of purchase and the date of maturity, would amortize the difference between the purchase price and the face value of the bonds held. In the case of bonds purchased at a discount income was increased and in the case of bonds purchased at a premium loss was taken each year, and…
1Opinion of the Court
*160OPINION.
Littleton:
There is no dispute as to the facts or the figures. Petitioner claims that it is entitled under the provisions of subsection (b) of section 212 of the Revenue Act of 1921 to have its *161net income computed in accordance with the method of accounting regularly employed in keeping its books and that its income for' any year from bonds held by it must be increased or decreased as the case may be in the amount of the amortization of the discount or premium at which such bonds were purchased; that in allowing the gain or loss from the sale of such bonds the basis to be employed is…
2Cases cited1 opinion
- New York Life Insurance v. EdwardsSupreme Court of the United States · 1926
3Cited by12 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- American Smelting & Refining Co. v. United StatesCourt of Appeals for the Third Circuit · 1942
- Banco de Ponce v. Secretario de HaciendaSupreme Court of Puerto Rico · 1959
- Midland-Ross Corp. v. United StatesDistrict Court, N.D. Ohio · 1963
- United States v. Botany Worsted MillsCourt of Appeals for the Third Circuit · 1938
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