Legal Opinion

O'Dell v. Commissioner

United States Tax Court

Decided June 20, 1956No. Docket No. 56301Published

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

  1. Blair v. First Trust & Savings Bank of MiamiCourt of Appeals for the Fifth Circuit · 1930
  2. Helvering v. Martin-Stubblefield, Inc.Court of Appeals for the Eighth Circuit · 1934
  3. O'Dell v. CommissionerUnited States Tax Court · 1956

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