Warner Co. v. Commissioner
United States Tax Court
On the record, held: 1. Where petitioner purchased at less than face value certain of its bonds with accrued interest coupons attached, which bonds had been issued at a discount, the gain realized on the principal of the bonds is to be determined by a proportionate allocation between principal and interest. 2. Where petitioner kept its books on an accrual basis, its liability for interest payments on its bonds became fixed on the dates specified in the original instrument…
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On the record, held: 1. Where petitioner purchased at less than face value certain of its bonds with accrued interest coupons attached, which bonds had been issued at a discount, the gain realized on the principal of the bonds is to be determined by a proportionate allocation between principal and interest. 2. Where petitioner kept its books on an accrual basis, its liability for interest payments on its bonds became fixed on the dates specified in the original instrument and the interest was then properly accrued and deductible. Such interest is not a proper item of deduction in a subsequent…
1Opinion of the Court
Warner Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Warner Co. v. Commissioner
Docket No. 7326
United States Tax Court
11 T.C. 419; 1948 U.S. Tax Ct. LEXIS 83;
September 27, 1948, Promulgated
Decision will be entered under Rule 50.
On the record, held:
1. Where petitioner purchased at less than face value certain of its bonds with accrued interest coupons attached, which bonds had been issued at a discount, the gain realized on the principal of the bonds is to be determined by a proportionate allocation between principal and interest.
2. Where petitioner kept its books on an…
2Cases cited8 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- American National Co. v. United StatesSupreme Court of the United States · 1927
- Palomar Laundry v. CommissionerUnited States Tax Court · 1946
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