Bryant v. Commissioner
United States Tax Court
1. In a prior proceeding between the same parties involving the year 1935, the issue submitted to the Board of Tax Appeals, and on review of the Board's decision to the Circuit Court of Appeals, was whether interest received on certain municipal bonds was exempt from tax.
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1. In a prior proceeding between the same parties involving the year 1935, the issue submitted to the Board of Tax Appeals, and on review of the Board's decision to the Circuit Court of Appeals, was whether interest received on certain municipal bonds was exempt from tax. Included in the net amount stated as the amount in controversy was an amount designated "Bonus on overpayments and penalties" which was not otherwise explained but which in fact represented premiums received on the redemption of bonds prior to maturity and penalties received on default in payment at the time of maturity.…
1Opinion of the Court
OPINION.
TurneR, Judge:
The respondent determined a deficiency of $4,-056.44 in the petitioner’s income tax for 1939. The issues presented are the correctness of the respondent’s action (1) in disallowing a deduction of $2,127.94 taken for charitable contributions; (2) in including in taxable income $136.02 representing the sum received by the petitioner as bonuses or premiums upon the redemption, prior to the date of maturity, of certain municipal bonds owned by her; and (3) in including in taxable income $971.02 received by petitioner on certain municipal bonds owned by her and representing…
2Cases cited4 opinions
- Cromwell v. County of SacSupreme Court of the United States · 1877
- New Orleans v. Citizens' BankSupreme Court of the United States · 1897
- Last Chance Mining Co. v. Tyler Mining Co.Supreme Court of the United States · 1895
- District Bond Co. v. CommissionerUnited States Tax Court · 1943
3Cited by8 opinions
- Maltine Co. v. CommissionerUnited States Tax Court · 1945
- Richmond, F. & P. R. Co. v. CommissionerUnited States Tax Court · 1974
- The Prudential Insurance Company of America v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1989
- Phoenix Mut. Life Ins. Co. v. CommissionerUnited States Tax Court · 1991
- Bryant v. CommissionerUnited States Tax Court · 1943
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