Legal Opinion
United States v. Harrison
Court of Appeals for the Fifth Circuit
Decided June 22, 1962No. 19059PublishedCited by 22 opinions
1Opinion of the Court
WISDOM, Circuit Judge.
This action for tax refunds presents the question whether amounts of original issue discount or interest received upon retirement of corporate bonds are taxable as capital gain or ordinary income.
In 1952 the taxpayers purchased original issue discount bonds due to mature in series over the next five years. As the bonds were redeemed, the taxpayers reported their gain as long-term capital gain. They rely on Section 117(f) of the Internal Revenue Code of 1939 and Section 1232(a) of the 1954 Code which provide that amounts received by the holder upon the retirement of bonds…
2Cases cited10 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Ferguson v. TabahCourt of Appeals for the Second Circuit · 1961
- Commissioner of Internal Revenue v. CaulkinsCourt of Appeals for the Sixth Circuit · 1944
5 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- United States v. Midland-Ross Corp.Supreme Court of the United States · 1965
- Schwartz v. CommissionerUnited States Tax Court · 1963
- Pattiz v. United StatesUnited States Court of Claims · 1963
- Joseph I. Lubin and Evelyn J. Lubin, and Estate of Joseph Eisner, Deceased, Helen Eisner, and Helen Eisner v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
17 more not listed; retrieve them via the Exa API.