Loose v. Commissioner
United States Board of Tax Appeals
1. Interest accrued on corporate bonds owned by decedent but not matured at time of his death becomes part of the corpus of his estate and when collected is not income to the estate. 2. Interest coupons matured prior to death of decedent on bonds of solvent corporations which would have paid the same on presentation and which coupons were not cashed by reason of the illness of decedent, held to have been constructively received by decedent during his lifetime and to…
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1. Interest accrued on corporate bonds owned by decedent but not matured at time of his death becomes part of the corpus of his estate and when collected is not income to the estate. 2. Interest coupons matured prior to death of decedent on bonds of solvent corporations which would have paid the same on presentation and which coupons were not cashed by reason of the illness of decedent, held to have been constructively received by decedent during his lifetime and to constitute income to him.
1Opinion of the Court
*172OPINION.
Van Fossan:
The issue raised by the facts in proceeding 8699 brings the case squarely within our decisions in William G. Frank, 6 B. T. A. 1071, and George Nichols, Executor, 10 B. T. A. 919. The bond interest which had accrued at the time of decedent’s death, though the coupons had not matured, represents, nevertheless, a debt due decedent. At his death it became a part of the corpus of his estate subject to the estate tax. Upon collection by the executrix there was a conversion of a debt into its equivalent in money, but the funds so derived did not constitute income to the estate. *173A.…
2Cited by11 opinions
- Security First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933
- Hamilton National Bank of Chattanooga v. CommissionerUnited States Board of Tax Appeals · 1933
- Sletteland v. CommissionerUnited States Tax Court · 1965
- Hamilton Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933
- City Bank Farmers Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933
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