Adrian & James, Inc. v. Commissioner
United States Tax Court
1. In 1925 and during a period from September 29, 1932, to April 21, 1937, petitioner, a personal holding company, purchased gold notes of a transit company with interest coupons attached. Default was made in payment of the notes and the final coupons attached on September 1, 1932, when they all matured, and shortly thereafter the transit company was placed in receivership.
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1. In 1925 and during a period from September 29, 1932, to April 21, 1937, petitioner, a personal holding company, purchased gold notes of a transit company with interest coupons attached. Default was made in payment of the notes and the final coupons attached on September 1, 1932, when they all matured, and shortly thereafter the transit company was placed in receivership. After receiving various payments on the indebtedness during the receivership, which payments were derived from interest on the bonds pledged as collateral to the notes and coupons, petitioner sold the notes and the final…
1Opinion of the Court
OPINION.
Tyson, Judge:
The first issue is whether the payments, or any portion thereof, received by the petitioner with respect to the Transit Co. 7 percent gold notes and attached coupons while the Transit Co. was in receivership, which payments were made out of interest collected on the bonds pledged as collateral thereto, constituted a return of capital rather than interest for the purpose of ascertaining the cost basis of such notes and coupons in connection with their sale in 1939. Respondent contends that the notes and coupons when acquired were acquired as one single piece of property…
2Cases cited2 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Helvering v. Metropolitan Edison Co.Supreme Court of the United States · 1939
3Cited by17 opinions
- Koppers Coal Co. v. CommissionerUnited States Tax Court · 1946
- Stanton Brewery v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Simon Jaglom and Marie Jaglom v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Koppers Company v. United StatesUnited States Court of Claims · 1955
- Jaglom v. CommissionerUnited States Tax Court · 1961
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