M. C. Parrish & Co. v. Commissioner
United States Tax Court
1. Petitioner's principal business was that of purchasing at a discount warrants issued by the State of Texas payable out of the general revenue fund. It did not purchase these warrants from the state, but purchased them from the original payees thereof and held them from six to nine months until they were called in by the state and paid.
Read the full summary
1. Petitioner's principal business was that of purchasing at a discount warrants issued by the State of Texas payable out of the general revenue fund. It did not purchase these warrants from the state, but purchased them from the original payees thereof and held them from six to nine months until they were called in by the state and paid. Held, for the taxable years 1937, 1939, and 1940, the difference between the cost to petitioner of the warrants purchased and the amount later collected from the state is includable in gross income under section 22 (a) of the Revenue Act of 1936 and of the…
1Opinion of the Court
OPINION..
Black. Judge:
As indicated in our opening statement, the questions presented by the assignments of error are: (1) Did the respondent err in failing and refusing to hold that the profits earned and collected by petitioner in each of the years 1937 1939, and 1940, with respect to warrants drawn by the treasurer of the State of Texas on the general revenue fund of the state, constituted interest on an obligation of the state specifically excluded from taxable income by section 22 (b) (4) of the Revenue Act of 1936 and of the Internal Revenue Code? (2) Did the respondent err in failing…
2Cases cited4 opinions
- Willcutts v. BunnSupreme Court of the United States · 1931
- Hale v. CommissionerUnited States Tax Court · 1942
- American Found. Co. v. CommissionerUnited States Tax Court · 1943
- American Liberty Oil Co. v. CommissionerUnited States Tax Court · 1942
3Cited by34 opinions
- Halle v. CommissionerUnited States Tax Court · 1946
- Lawrence v. CommissionerUnited States Tax Court · 1957
- Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
- Brown v. CommissionerUnited States Tax Court · 1961
- George Slaff v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
29 more not listed; retrieve them via the Exa API.