Legal Opinion

Andrews v. Commissioner

United States Board of Tax Appeals

Decided March 12, 1942No. Docket Nos. 97628, 97629, 97630, 97631, 99353Published

Petitioners, as holders of certain "6% Convertible Obligations" of the Associated Gas & Electric Co., received in 1936 in payment of accrued interest 4 percent interest-bearing scrip, subordinated in principal to certain senior securities of the company. The scrip had a market value, established by numerous sales, of 35 cents for every dollar of face value. The petitioners were on the cash basis.

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Petitioners, as holders of certain "6% Convertible Obligations" of the Associated Gas & Electric Co., received in 1936 in payment of accrued interest 4 percent interest-bearing scrip, subordinated in principal to certain senior securities of the company. The scrip had a market value, established by numerous sales, of 35 cents for every dollar of face value. The petitioners were on the cash basis. Their agent, who prepared and filed their returns, failed to include this scrip in 1936 in petitioners' income tax returns on advice of counsel. Held, that the scrip constituted taxable income, and…

1Opinion of the Court

CHARLOTTE L. ANDREWS, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Andrews v. Commissioner

Docket Nos. 97628, 97629, 97630, 97631, 99353.

United States Board of Tax Appeals

46 B.T.A. 607; 1942 BTA LEXIS 844;

March 12, 1942, Promulgated

Petitioners, as holders of certain "6% Convertible Obligations" of the Associated Gas & Electric Co., received in 1936 in payment of accrued interest 4 percent interest-bearing scrip, subordinated in principal to certain senior securities of the company. The scrip had a market value, established by numerous sales, of 35 cents for every dollar…

2Cases cited5 opinions

  1. McKitterick v. CommissionerUnited States Board of Tax Appeals · 1940
  2. Staley v. CommissionerUnited States Board of Tax Appeals · 1940
  3. Robertson v. RoutzahnCourt of Appeals for the Sixth Circuit · 1935
  4. Newberry v. CommissionerUnited States Board of Tax Appeals · 1939
  5. Andrews v. CommissionerUnited States Board of Tax Appeals · 1942

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