Jacobson v. Commissioner
United States Tax Court
1. Petitioner is the owner in Chicago, Illinois, of a leasehold and buildings thereon. In 1925 petitioner borrowed $ 90,000 on the property and executed his negotiable bonds therefor. Some of the bonds have been paid off and retired from time to time and the interest has at all times been paid. On January 1, 1938, $ 51,750 of such bonds was still outstanding. In the years 1938, 1939, and 1940 petitioner acquired some of these bonds at less than their face value.
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1. Petitioner is the owner in Chicago, Illinois, of a leasehold and buildings thereon. In 1925 petitioner borrowed $ 90,000 on the property and executed his negotiable bonds therefor. Some of the bonds have been paid off and retired from time to time and the interest has at all times been paid. On January 1, 1938, $ 51,750 of such bonds was still outstanding. In the years 1938, 1939, and 1940 petitioner acquired some of these bonds at less than their face value. Some of them were acquired by petitioner directly from the bondholders themselves after negotiations with them. Some were acquired…
1Opinion of the Court
OPINION.
Black, Judge:
The main issue in this proceeding, which is common to all three of the taxable years, is whether petitioner is taxable on the difference between the face value of certain bonds upon which he was liable as the issuer and the price for which he purchased some of these bonds during each of the taxable years. The facts as to the amounts of such bonds purchased and the price which was paid for them are not in dispute. The controversy between the parties concerns itself only with the manner, form, and effect of the purchases.
It is respondent’s contention that it is a case…
2Cases cited4 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Nelson v. CommissionerUnited States Tax Court · 1946
- Fifth Avenue-14th Street Corp. v. CommissionerUnited States Tax Court · 1943
3Cited by19 opinions
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Abraham v. CommissionerUnited States Tax Court · 1947
- Liberty Finance Service, Inc. v. CommissionerUnited States Tax Court · 1960
- Edmont Hotel Co. v. CommissionerUnited States Tax Court · 1948
- Nutter v. CommissionerUnited States Tax Court · 1946
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