Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 54-66

1954-1 C.B. 128

Sec. 165
Sec. 171
Sec. 1232

Full Text

Rev. Rul. 54-66

Evidences of indebtedness issued by any corporation (including like obligations issued by a Government or political subdivision thereof) without interest coupons or not in registered form do not constitute `bonds' within the meaning of that term as used in section 125(d) of the Internal Revenue Code. Therefore, premiums paid upon the acquisition thereof are not amortizable under the provisions of section 125(b) of the Code. Neither are such evidences of indebtedness the type of obligations comprehended by section 117(f) of the Code. Consequently, any excess of cost or other basis over the amount realized upon redemption of such obligations is deductible as an ordinary loss under section 23(e) or section 23(f) of the Code.