Bettendorf v. Commissioner
United States Board of Tax Appeals
1. Interest awarded in a decree against a trustee as damages for the conversion of the trust property, is not interest on indebtedness, within the meaning of section 214(a)(2) of the Revenue Acts of 1918 and 1921. 2. A judgment constitutes a debt, and interest paid thereon is properly deductible in ascertaining net income subject to tax.
1Opinion of the Court
*382OPINION.
Marquette: The only question presented by this appeal is whether or not the taxpayer, in computing his net income for the years 1920 and 1921, is entitled to deduct the amounts of $319,468.37 and $4,654.65, respectively, paid by him to Elizabeth H. Bettendorf in those years, under the circumstances set forth in the findings of fact herein. The taxpayer contends that the payments in question represented interest on indebtedness and are deductible under the provisions of section 214 (a) (2) of the Kevenue Acts of 1918 and 1921, which respectively provide that, in computing net income,…
2Cases cited11 opinions
- Morley v. Lake Shore & Michigan Southern Railway Co.Supreme Court of the United States · 1892
- Redfield v. Ystalyfera Iron Co.Supreme Court of the United States · 1884
- Provident Savings Life Assurance Society v. FordSupreme Court of the United States · 1885
- Ambler v. WhippleIllinois Supreme Court · 1891
- Doyle v. BurnsSupreme Court of Iowa · 1904
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3Cited by15 opinions
- Midkiff v. CommissionerUnited States Tax Court · 1991
- Sharp v. CommissionerUnited States Tax Court · 1980
- District of Columbia v. National Bank of WashingtonDistrict of Columbia Court of Appeals · 1981
- Du Pont v. DeputyDistrict Court, D. Delaware · 1938
- Hewitt v. CommissionerUnited States Board of Tax Appeals · 1934
10 more not listed; retrieve them via the Exa API.