Jaglom v. Commissioner
United States Tax Court
Capital Gain or Ordinary Income -- Sale of Accrued Interest on Indebtedness. -- Petitioners bought "flat," bonds on which there was accrued interest in default and later sold the same bonds flat for an amount in excess of the face amount of the bonds plus the remaining balance of the unpaid defaulted interest at the time of purchase.
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Capital Gain or Ordinary Income -- Sale of Accrued Interest on Indebtedness. -- Petitioners bought "flat," bonds on which there was accrued interest in default and later sold the same bonds flat for an amount in excess of the face amount of the bonds plus the remaining balance of the unpaid defaulted interest at the time of purchase. A portion of the amount received on the sale of the bonds represents the payment of interest which accrued on the bonds while they were owned by the petitioners, and that part of the amount received on the sale is taxable to the petitioners as ordinary income…
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency of $3,800.35 in the petitioners’ income tax for 1954 and an addition under section 294 (d) (2) for substantial understatement in the declaration of estimated tax. The only issue for decision is whether the petitioners are taxable with ordinary income representing interest on Missouri Pacific bonds that accrued while the petitioners owned those bonds. The facts have been presented by a stipulation which is adopted as the findings of fact.
The petitioners filed a joint income tax return for 1954 with the district director of…
2Cases cited6 opinions
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
- Fisher v. CommissionerUnited States Tax Court · 1952
- Shattuck v. CommissionerUnited States Tax Court · 1955
- Tobey v. CommissionerUnited States Tax Court · 1956
- Adrian & James, Inc. v. CommissionerUnited States Tax Court · 1945
1 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Simon Jaglom and Marie Jaglom v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Leavin v. CommissionerUnited States Tax Court · 1962
- Bolnick v. CommissionerUnited States Tax Court · 1965
- Crocker v. CommissionerUnited States Tax Court · 1962
- Jones v. CommissionerUnited States Tax Court · 1963
16 more not listed; retrieve them via the Exa API.