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GIBBONS v. COMMISSIONER

Docket No. 75124.

37 T.C. 569 (1961)

RICHARD B. GIBBONS AND MARY LOUISE GIBBONS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 27, 1961.

Attorney(s) appearing for the Case

Kenneth S. Carey, Esq., for the petitioners.

William T. Ivey, Jr., Esq., for the respondent.

OPINION.

PIERCE, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1955 in the amount of $2,315.50. Petitioners allege that there is an overpayment of said tax, in the amount of $138.46.

The sole issue for decision is: Whether fully earned increments on 15-year investment certificates issued by a corporation in registered form — representing the difference between the issuance prices of the certificates...

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