Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 62-93

1962-1 C.B. 137

Sec. 1037

IRS Headnote

Under section 1037(a) of the Internal Revenue Code of 1954, no gain or loss will be recognized upon the exchange of the 3 percent Treasury Bonds of 1964 or the 2 5/8 percent Treasury Bonds of 1965 as offered by Department Circular, Public Debt Series No. 4-62.

Full Text

Rev. Rul. 62-93

In Treasury Department Circular, Public Debt Series No. 4-62, dated February 19, 1962, 27 F.R. 1855, the Secretary of the Treasury offered 4 percent Treasury Bonds of 1971 in exchange for other Treasury Bonds as follows:

(1) at par in exchange for 3 percent Treasury Bonds of 1964, dated February 14, 1958, due February 15, 1964; or

(2) at 102 percent of their face value in exchange for 2 5/8 percent Treasury Bonds of 1965, dated June 15, 1958, due February 15, 1965.

The income derived from the bonds is subject to all taxes imposed under the Internal Revenue Code of 1954. The bonds are subject to estate, inheritance, gift or other excise taxes, whether Federal or State, but are exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the possessions of the United States, or by any local taxing authority.

The bonds will be acceptable to secure deposits of public moneys. However, they will not be acceptable in payment of taxes.

Pursuant to the provisions of section 1037(a) of the Code, the Secretary of the Treasury has declared that no gain or loss shall be recognized, for Federal income tax purposes, upon the exchange with the United States of 3 percent Treasury Bonds of 1964 or 2 5/8 percent Treasury Bonds of 1965 solely for the 4 percent Treasury Bonds of 1971 as offered by Department Circular, Public Debt Series No. 4-62, supra .

Gain or loss, if any, upon the obligations surrendered in exchange will be taken into account upon the disposition or redemption of the new obligations.