Legal Opinion
Simon Jaglom and Marie Jaglom v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 4, 1962No. 27208_1PublishedCited by 36 opinions
1Opinion of the Court
LUMBARD, Chief Judge.
The sole question to be decided is whether that portion of the proceeds from the “flat” sale of defaulted bond which is allocable to interest accrued while the taxpayers held the bonds is taxable as ordinary income or capital gain. We hold that it is ordinary income.
On March 15, 1950 the taxpayers purchased $50,000 face amount of Missouri Pacific Railroad Company 5% bonds upon which interest of $20,000, accrued from March 1, 1942 to March 1, 1950, was in default. These bonds were purchased “flat,” i. e., without allocation of the purchase price between interest and…
2Cases cited31 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
- Bessie Lasky and Jesse L. Lasky v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- Scott A. Walker v. Roger Endell, Director, of the Alaska Department of CorrectionsCourt of Appeals for the Ninth Circuit · 1988
26 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- United States v. Midland-Ross Corp.Supreme Court of the United States · 1965
- Western Plains Service Corporation, a South Dakota Corporation v. Ponderosa Development Corporation, a Wyoming Corporation, and Francis H. McVayCourt of Appeals for the Tenth Circuit · 1985
- United States v. HarrisonCourt of Appeals for the Fifth Circuit · 1962
- Bolnick v. CommissionerUnited States Tax Court · 1965
- Carmelo Candiano v. Moore-Mccormack Lines, Inc. v. John W. McGrath Corp., Third PartyCourt of Appeals for the Second Circuit · 1969
31 more not listed; retrieve them via the Exa API.