Starr v. Commissioner
United States Tax Court
Petitioner, on April 9, 1958, ordered through his broker K, at a price above par, $ 9 million face amount of U.S. Treasury 2 3/8-percent bonds due June 15, 1958. Bondholders had the privilege of exchanging these bonds for a new issue of 2 5/8-percent bonds due in 1965. Petitioner did not put up cash for margin or apply for a loan. K ordered bonds for petitioner and others from G, a New York broker.
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Petitioner, on April 9, 1958, ordered through his broker K, at a price above par, $ 9 million face amount of U.S. Treasury 2 3/8-percent bonds due June 15, 1958. Bondholders had the privilege of exchanging these bonds for a new issue of 2 5/8-percent bonds due in 1965. Petitioner did not put up cash for margin or apply for a loan. K ordered bonds for petitioner and others from G, a New York broker. G acquired the bonds and sold them at cost to P under a repurchase agreement permitting either party to reverse the sale. P collected the interest and exchanged the maturing bonds for the new…
1Opinion of the Court
Bkuce, Judge:
Respondent determined deficiencies in income tax for the calendar years 1958 and 1959 in the respective amounts of $94,283.02 and $3,556.57. The issues remaining for decision are whether petitioners are entitled to a deduction in 1958 for amortization of bond premium in the amount of $39,375 or, in the alternative, for an amount of $21,093.75 paid in settlement of a claim resulting from a transaction entered into for profit.
FINDINGS OF FACT
The stipulation of facts and the exhibits attached thereto are incorporated herein by this reference. Respondent does not admit that the words…
2Cases cited6 opinions
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Maysteel Products, Inc. v. CommissionerUnited States Tax Court · 1960
- Maysteel Products, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Industrial Research Products, Inc. v. CommissionerUnited States Tax Court · 1963
- Herbert Humphreys and Wilda Humphreys, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1962
1 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Lemmen v. CommissionerUnited States Tax Court · 1981
- Ginsburg v. CommissionerUnited States Tax Court · 1976
- Holladay v. CommissionerUnited States Tax Court · 1979
- Holladay v. CommissionerUnited States Tax Court · 1979
- Lemmen v. CommissionerUnited States Tax Court · 1981
1 more not listed; retrieve them via the Exa API.