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JAGLOM v. COMMISSIONER

Docket No. 77152.

36 T.C. 126 (1961)

SIMON JAGLOM AND MARIE JAGLOM, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 20, 1961.

Attorney(s) appearing for the Case

Saul Duff Kronovet, Esq., for the petitioners.

Norman L. Rapkin, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined a deficiency of $3,800.35 in the petitioners' income tax for 1954 and an addition under section 294(d)(2) for substantial understatement in the declaration of estimated tax. The only issue for decision is whether the petitioners are taxable with ordinary income representing interest on Missouri Pacific bonds that accrued while the petitioners owned those bonds. The facts have been presented by a...

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