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HOOD v. COMMISSIONER

Docket No. 84613.

20 T.C.M. 1140 (1961)

T.C. Memo. 1961-231

Clifford F. Hood and Mary T. Hood v. Commissioner.

United States Tax Court.

Filed August 16, 1961.

Attorney(s) appearing for the Case

Jerome C. Bachrach, Esq., 2316 Farmers Bank Bldg., Pittsburgh, Pa., Sidney Hoffman, Esq., and Stephen M. Piga, Esq., for the petitioners. Gerald Backer, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined deficiencies in income tax for 1956 to 1957 in the amounts of $63,510.77 and $87,261.40, respectively. The issues presented are (1) whether petitioner is entitled to interest deductions claimed in 1956 and 1957, (2) whether the difference between the purchase price and maturity price of certain Treasury notes constitutes long-term capital gain or the realization of interest...

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