FACTS: The trial court held that respondent taxpayer did not realize a taxable gain from the purchase of its own bonds on the open market at less than their par value, which it had received when it issued them.
Upon the petition for certiorari review by the United States, the United States Supreme Court reviewed § 213(a) of the Revenue Act of November 23, 1921, and held that gross income included gains or profits and income derived from any source whatever.
CONCLUSION: The court reversed a judgment holding that respondent taxpayer did not realize a taxable gain from the purchase of its own bonds on the open market for less than it had received for them. The court concluded that respondent made a clear gain in a certain amount previously offset by the obligation of bonds.
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