Emery v. Commissioner
United States Tax Court
1. The city of Philadelphia offered to exchange new bonds for outstanding bonds, representing a part of its indebtedness, under a refinancing plan whereby the exchange was optional with the bondholder and was subject to a fee of 1 per cent of the face value of the bond. The new bond was of a face value equal to that of the old bond, but had different maturity and call dates and bore a lesser rate of interest after a date fixed by the first call date of the old bond.
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1. The city of Philadelphia offered to exchange new bonds for outstanding bonds, representing a part of its indebtedness, under a refinancing plan whereby the exchange was optional with the bondholder and was subject to a fee of 1 per cent of the face value of the bond. The new bond was of a face value equal to that of the old bond, but had different maturity and call dates and bore a lesser rate of interest after a date fixed by the first call date of the old bond. Some old bonds remained outstanding and were sold on the market at prices differing from those at which new bonds were sold.…
1Opinion of the Court
Thomas Emery, Petitioner, v. Commissioner of Internal Revenue, Respondent
Emery v. Commissioner
Docket No. 6106
United States Tax Court
8 T.C. 979; 1947 U.S. Tax Ct. LEXIS 209;
May 7, 1947, Promulgated
Decision will be entered for the respondent.
1. The city of Philadelphia offered to exchange new bonds for outstanding bonds, representing a part of its indebtedness, under a refinancing plan whereby the exchange was optional with the bondholder and was subject to a fee of 1 per cent of the face value of the bond. The new bond was of a face value equal to that of the old bond, but had different…
Also in this document: Dissent · LeMire; Dissent · Opper.
2Cases cited8 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Weiss v. StearnSupreme Court of the United States · 1924
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- United States v. BekinsSupreme Court of the United States · 1938
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