Hewitt v. Commissioner
United States Board of Tax Appeals
Petitioner at various times between 1921 and 1928 purchased, for a total consideration of $274,110.16, bonds having a total face value of $1,000,000, and defaulted matured interest coupons attached to the bonds having a total face value of $561,925. During 1928 and 1929 petitioner received $24,500 and $25,000, in payment of coupons dated July 2, 1913, and January 2, 1914, respectively.
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Petitioner at various times between 1921 and 1928 purchased, for a total consideration of $274,110.16, bonds having a total face value of $1,000,000, and defaulted matured interest coupons attached to the bonds having a total face value of $561,925. During 1928 and 1929 petitioner received $24,500 and $25,000, in payment of coupons dated July 2, 1913, and January 2, 1914, respectively. Held, that petitioner, being a purchaser of bonds and defaulted interest coupons attached thereto, their cost represented a capital investment, and under such circumstances, the collection of the purchased…
1Opinion of the Court
OPINION.
Black:
These proceedings, duly consolidated, are for the rede-termination of deficiencies in income taxes for the years 1928 and 1929 in the amounts of $7,335.87 and $5,877.97, respectively. The amounts in controversy are $6,125 for 1928 and $5,000 for 1929.
The question involved is whether the respondent erred in including in petitioner’s income $24,500 in 1928 and $25,000 in 1929 as interest received by petitioner in those years on certain bonds purchased by petitioner at various times between 1921 and 1928, when, at the time of purchase, the obligor of the bonds had been in default…
2Cases cited8 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Burnet v. LoganSupreme Court of the United States · 1931
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- John Hancock Mut. Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
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3Cited by10 opinions
- Simon Jaglom and Marie Jaglom v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Clyde C. Pierce Corp. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1941
- National City Lines, Inc. v. United StatesCourt of Appeals for the Third Circuit · 1952
- Commissioner of Internal Revenue v. Carman. Carman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
- First Kentucky Company v. GrayDistrict Court, W.D. Kentucky · 1960
5 more not listed; retrieve them via the Exa API.