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PATTIZ v. UNITED STATES

Nos. 219-61, 244-61, 245-61, 282-61 to 287-61.

311 F.2d 947 (1963)

Oscar S. and Leona W. PATTIZ v. UNITED STATES of America. Alex DEUTSCH and Eleanor Deutsch v. UNITED STATES of America. Lester DEUTSCH and Betty Deutsch v. UNITED STATES of America. Rosella FAMILIAN, as Trustee of the Sondra J. Familian Trust v. UNITED STATES of America. Rosella FAMILIAN, as Trustee of the Gary R. Familian Trust v. UNITED STATES of America. Isadore FAMILIAN and Sunny Familian v. UNITED STATES of America. Isadore FAMILIAN as Trustee of the Arnold Familian Trust v. UNITED STATES of America. Rosella FAMILIAN, as Executrix of the Estate of George Familian, Deceased, and Rosella Familian, v. UNITED STATES of America. Annette Familian SHAPIRO v. UNITED STATES of America.

United States Court of Claims.

Rehearing Denied March 6, 1963.

Attorney(s) appearing for the Case

Arthur B. Willis, Los Angeles, Cal., for plaintiffs. John P. Lipscomb, Washington, D. C., was on the briefs.

Cynthia Holcomb, Washington, D. C., with whom was Asst. Atty. Gen. Louis F. Oberdorfer, for defendant. Edward S. Smith, Lyle M. Turner, Philip R. Miller, and George Willi, Washington, D. C., were on the briefs.

WHITAKER, Judge.

The issue presented in these cases is whether the difference between the purchase price of registered notes and the price at which the payor redeemed them is ordinary income or a capital gain.

Plaintiffs rely on section 117(f) of the Internal Revenue Code of 1939, as amended, which provides:

"For the purposes of this chapter, amounts received by the holder upon the retirement of bonds, debentures, notes, or certificates or other evidences...

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