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LLOYD v. COMMISSIONER OF INTERNAL REVENUE

No. 8976.

154 F.2d 643 (1946)

LLOYD v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Decided March 4, 1946.

Attorney(s) appearing for the Case

Wm. Clarke Mason, of Philadelphia, Pa. (Jesse R. Fillman, W. James MacIntosh, Owen Biddle and Caspar W. B. Townsend, all of Philadelphia, Pa., on the brief), for petitioner.

Morton K. Rothschild, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Helen R. Carloss, and Bernard Chertcoff, Sp. Asst. to the Atty. Gen., on the brief), for respondent.

Before GOODRICH, McLAUGHLIN, and O'CONNELL, Circuit Judges.

O'CONNELL, Circuit Judge.

This petition for review of the Tax Court's decision presents a rather narrow question for our consideration. We are required to pass on the correctness of the Commissioner's holding that proceeds from the sale of certain unmatured coupons clipped from tax-exempt municipal bonds (later sold) were includible in taxable income of the seller. The taxpayer contends that the proceeds in question were tax-exempt as being interest upon the obligation...

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