Legal Opinion

Afia Finance Corp. v. Commissioner

United States Tax Court

Decided November 21, 1963No. Docket No. 361-62Published

1. Held, under the provisions of section 127, I.R.C. 1939, the petitioner sustained in 1941 a war loss on German External Loan 1924 7 percent Bonds, due October 15, 1949, sometimes referred to as old bonds, and on the facts the recovery date of the bonds was on or about May 13, 1958, or a prior date in that year. 2. In 1958 the petitioner, pursuant to provisions of the London Agreement and Annex I thereto, received: (1) For its old bonds a like amount in face value of German…

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1. Held, under the provisions of section 127, I.R.C. 1939, the petitioner sustained in 1941 a war loss on German External Loan 1924 7 percent Bonds, due October 15, 1949, sometimes referred to as old bonds, and on the facts the recovery date of the bonds was on or about May 13, 1958, or a prior date in that year. 2. In 1958 the petitioner, pursuant to provisions of the London Agreement and Annex I thereto, received: (1) For its old bonds a like amount in face value of German External Loan 1924, Extension Issue 1953, 5 1/2% Dollar Bonds due October 15, 1969, sometimes referred to as new bonds;…

1Opinion of the Court

Afia Finance Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Afia Finance Corp. v. Commissioner

Docket No. 361-62

United States Tax Court

41 T.C. 255; 1963 U.S. Tax Ct. LEXIS 16;

November 21, 1963, Filed

Decision will be entered under Rule 50.

1. Held, under the provisions of section 127, I.R.C. 1939, the petitioner sustained in 1941 a war loss on German External Loan 1924 7 percent Bonds, due October 15, 1949, sometimes referred to as old bonds, and on the facts the recovery date of the bonds was on or about May 13, 1958, or a prior date in that year.

2. In 1958 the…

2Cases cited9 opinions

  1. Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
  2. Simon Jaglom and Marie Jaglom v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
  3. Feinstein v. CommissionerUnited States Tax Court · 1955
  4. Kenmore v. CommissionerUnited States Tax Court · 1952
  5. Kenmore v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953

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