Apkin v. Commissioner
United States Tax Court
86 T.C. 692 (1986)
- Written by Joe Cox, JD
Facts
Dora Apkin purchased a series of United States Series E Savings Bonds between 1948 and 1959. The bonds had a total face value of $5,125, and Dora paid $3,843.75. The bonds were payable to Dora or her son, Phillip Apkin (plaintiff), as co-owners. Dora died in 1979, at which time she had not redeemed any of the bonds. Phillip redeemed the bonds in 1981 but failed to report the interest received on the bonds when they were paid. Accordingly, the Commissioner of Internal Revenue (defendant) filed a notice of deficiency. Phillip later admitted he was responsible for the interest accruing between 1979, when Dora died, and 1981, when he cashed in the bonds. However, Phillip still disputed the interest from the purchase dates until his mother’s death. Dora had never reported any of the interest as income during her lifetime, as Dora could have elected to do. Dora had not filed federal income-tax returns, as she lacked enough income to require a filing, even if Dora had included the interest as income.
Rule of Law
Issue
Holding and Reasoning (Raum, J.)
What to do next…
Here's why 806,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
