Joseph B. Zinn - Page 6




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          deficiency in issue.  Higbee v. Commissioner, 116 T.C. 438                  
          (2001).                                                                     
               According to Form PDF 5329 provided by the Bureau, “interest           
          received from Treasury bills is the difference between the                  
          purchase price and the redemption amount -- not the discount                
          payment received when a bill is issued.  Therefore, INTEREST FROM           
          BILLS IS TAXABLE AND REPORTABLE TO THE IRS FOR THE YEAR THE BILL            
          MATURES.”  Accord Vance v. Commissioner, T.C. Memo. 1989-95.                
               Despite petitioner’s contention that the U.S. Treasury bills           
          in issue were purchased in 1998, evidence in the record clearly             
          shows that the bills were indeed purchased in 1997 and matured in           
          1998.  We find that petitioner failed to report the interest                
          income on the Treasury bills as shown above.  Accordingly,                  
          respondent is sustained as to the interest on the U.S. Treasury             
          bills.                                                                      
               Under section 1272(a)(1), there shall be included in the               
          gross income of the holder of any debt instrument having original           
          issue discount issued after July 1, 1982, the sum of the daily              
          portions of the original issue discount for each day during the             
          taxable year on which he held the debt instrument.  The term                
          “debt instrument” includes inflation-indexed debt instruments.              
          Sec. 1275(a); sec. 1.1275-7(a), Income Tax Regs.  Section 1.1275-           
          7(a), Income Tax Regs., provides two methods to calculate the               
          original issue discount on inflation-indexed debt instruments:              






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