original issue discount
Definitions from Case Law · United States Supreme Court
Definitions from Case Law
From 381 U.S. 54 - United States v. Midland-Ross Corp. · 1965Most cited · 188 citing opinions
Earned original issue discount serves the same function as stated interest, concededly ordinary income and not a capital asset; it is simply 'compensation for the use or forbearance of money.' Unlike the typical case of capital appreciation, the earning of discount to maturity is predictable and measurable, and is 'essentially a substitute for payments which § 22(a) expressly characterizes as gross income; thus it must be regarded as ordinary income.
How often courts cite the case defining “original issue discount”
Court decisions citing the opinion that defined “original issue discount” — 185 in all, by decade. Counts are citations to the defining case as a whole, not verified uses of the term. The dip in the most recent years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the latest years.