Emil G. Seip v. Commissioner
United States Tax Court
1.In 1924 petitioner acquired $10,000 face value of bonds, due in 1943, of a silk manufacturing corporation at a cost of $10,000. Interest on these bonds was paid until in 1931 when the corporation defaulted in its interest payments and no more interest payments were made from that time up to and including the time when petitioner, in 1941, sold the bonds in a bona fide sale for $150 cash.
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1.In 1924 petitioner acquired $10,000 face value of bonds, due in 1943, of a silk manufacturing corporation at a cost of $10,000. Interest on these bonds was paid until in 1931 when the corporation defaulted in its interest payments and no more interest payments were made from that time up to and including the time when petitioner, in 1941, sold the bonds in a bona fide sale for $150 cash. Held, under the facts, that petitioner is entitled to take his loss in 1941, the year of sale, limited by the long-term capital loss provisions of section 117, Internal Revenue Code. 2. On the facts it is…
1Opinion of the Court
Emil G. Seip v. Commissioner.
Emil G. Seip v. Commissioner
Docket No. 6324.
United States Tax Court
1946 Tax Ct. Memo LEXIS 73; 5 T.C.M. (CCH) 833; T.C.M. (RIA) 46230;
September 30, 1946
1.In 1924 petitioner acquired $10,000 face value of bonds, due in 1943, of a silk manufacturing corporation at a cost of $10,000. Interest on these bonds was paid until in 1931 when the corporation defaulted in its interest payments and no more interest payments were made from that time up to and including the time when petitioner, in 1941, sold the bonds in a bona fide sale for $150 cash. Held, under the facts,…
2Cases cited3 opinions
- General Lead Batteries Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Michel v. CommissionerUnited States Board of Tax Appeals · 1941
- Henry v. CommissionerUnited States Tax Court · 1946