SHATTUCK v. COMMISSIONER

Docket No. 51263.

25 T.C. 416 (1955)

WARNER A. SHATTUCK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 9, 1955.


Attorney(s) appearing for the Case

Robert C. Harris, Esq., for the petitioner.

Aaron S. Resnik, Esq., for the respondent.


The respondent determined a deficiency in income tax for 1950 in the amount of $7,616.58. All of the deficiency is in dispute. The issue is whether upon petitioner's sale to the issuing corporation of interest-bearing, registered bonds, on which interest had accrued but was unpaid, the whole amount of the proceeds over cost was reportable as long-term capital gain, as petitioner contends, or whether a pro rata proportion of the proceeds represented realization of accrued...

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