Ades v. Commissioner
United States Tax Court
A partnership and certain individuals purchased convertible and callable bonds at a premium. Before amortizing the part of that premium not attributable to the conversion feature, they converted the bonds into common stock. Held, the unamortized part of such bond premium at the date of conversion is not an allowable deduction in the year of conversion.
1Opinion of the Court
OPINION.
Foerester, Judge:
Respondent has determined deficiencies in income tax and additions thereto as follows:
[[Image here]]
Certain adjustments Rave been conceded by all petitioners, and petitioners in Docket ISTo. 79391 have abandoned tbe question of the addition to tax for 1955.
The sole issue remaining for consideration is whether petitioners may deduct the premiums paid for certain convertible and callable bonds during the year in which they were converted into the stock of the issuing corporation.
All of the facts have been stipulated and are so found.
All petitioners are individuals who…
2Cases cited16 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Zemel v. RuskSupreme Court of the United States · 1965
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
11 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Ades v. CommissionerUnited States Tax Court · 1962
- Ades v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Robert Ades v. Commissioner of Internal Revenue, Albert J. Ades and Sylvia Ades v. Commissioner of Internal Revenue, Alan Ades and Ruth Ades v. Commissioner of Internal Revenue, Joseph Ades and Rachel Ades v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963