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COMMISSIONER v. JACOBSON

Nos. 32 and 33.

336 U.S. 28 (1949)

69 S.Ct. 358

93 L.Ed. 477

COMMISSIONER OF INTERNAL REVENUE v. JACOBSON.

Supreme Court of United States.

Decided January 17, 1949.

Attorney(s) appearing for the Case

Arnold Raum argued the cause for petitioner. With him on the brief were Solicitor General Perlman, Assistant Attorney General Caudle, Ellis N. Slack, Lee A. Jackson, Hilbert P. Zarky, Morton K. Rothschild and Philip Elman.

Theodore R. Colborn argued the cause for respondent. With him on the brief were Wm. B. Cockley and Walter A. Marting.

MR. JUSTICE BURTON delivered the opinion of the Court.

This decision applies the federal income tax to gains derived by a debtor from his purchase of his own obligations at a discount and his consequent control over their discharge. It presents the specific question whether a solvent natural person, in straitened financial circumstances, must include in his gross income for federal income tax purposes the difference between...

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