O'Dell v. Commissioner
United States Tax Court
During the taxable years petitioners were partners in the small loan business. When loans were made to a borrower petitioners took a note for the principal loaned him to which was added certain charges which petitioners called fees and commissions. The note was either payable in 1 monthly installment or in 6 monthly installments of equal amounts, as the case might be.
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During the taxable years petitioners were partners in the small loan business. When loans were made to a borrower petitioners took a note for the principal loaned him to which was added certain charges which petitioners called fees and commissions. The note was either payable in 1 monthly installment or in 6 monthly installments of equal amounts, as the case might be. Each note contained a provision which read: "It is hereby agreed any payments made on this note shall be applied first to the principal." When a borrower made payments on his note the payments were first credited to principal…
1Opinion of the Court
Ishmael S. O'Dell and Mary J. O'Dell, Petitioners, v. Commissioner of Internal Revenue, Respondent
O'Dell v. Commissioner
Docket No. 56301
United States Tax Court
26 T.C. 592; 1956 U.S. Tax Ct. LEXIS 153;
June 20, 1956, Filed
Decision will be entered for the petitioners.
During the taxable years petitioners were partners in the small loan business. When loans were made to a borrower petitioners took a note for the principal loaned him to which was added certain charges which petitioners called fees and commissions. The note was either payable in 1 monthly installment or in 6 monthly installments of…
2Cases cited3 opinions
- Blair v. First Trust & Savings Bank of MiamiCourt of Appeals for the Fifth Circuit · 1930
- Helvering v. Martin-Stubblefield, Inc.Court of Appeals for the Eighth Circuit · 1934
- O'Dell v. CommissionerUnited States Tax Court · 1956