He said senior notes of Cablevision Inc . that mature in April 2011 and have a 7 | percent interest coupon are now trading at 82.5 cents on the dollar, up from a low of 70 cents on Aug . 7; he expects the price to rise further.
32.
The issue before the Court was whether the gift of interest coupons, during the donor s taxable year, detached from the bonds, is considered as the realization of income taxable to the donor, or if the gift of the coupons effectively diverts the payments of interest to the donee.
33.
He said senior notes of Cablevision Inc . that mature in April 2011 and have a 7 | percent interest coupon are now trading at 82 . 5 cents on the dollar, up from a low of 70 cents on Aug . 7; he expects the price to rise further.
34.
The United States acquiesces in the judgment in respect to the first of these claims, but contends that the Act of July 14, 1870, imposed a tax upon interest coupons that were paid out of the corporation earnings for 1871, although such payment was not due nor made until January 1, 1872.
35.
It appeared that certain interest coupons of the bonds of the company were payable and were paid on the first days of September and November 1870, and that certain other interest coupons of the same company were payable on the first day of January 1872, and were then paid out of its earnings made prior to that date and during the year 1871.
36.
It appeared that certain interest coupons of the bonds of the company were payable and were paid on the first days of September and November 1870, and that certain other interest coupons of the same company were payable on the first day of January 1872, and were then paid out of its earnings made prior to that date and during the year 1871.
