Samueli v. Comm'r
United States Tax Court
Ps-S purchased an approximate $ 1.64 billion of securities from F in October 2001 and simultaneously transferred the securities back to F pursuant to F's promise to transfer identical securities to Ps-S on Jan. 15, 2003. The agreement between Ps-S and F allowed Ps-S to require an earlier transfer of the identical securities only by terminating the transaction on July 1 or Dec. 2, 2002. Ps-S did not require an earlier transfer and sold the securities to F on Jan. 15, 2003. Ps…
Read the full summary
Ps-S purchased an approximate $ 1.64 billion of securities from F in October 2001 and simultaneously transferred the securities back to F pursuant to F's promise to transfer identical securities to Ps-S on Jan. 15, 2003. The agreement between Ps-S and F allowed Ps-S to require an earlier transfer of the identical securities only by terminating the transaction on July 1 or Dec. 2, 2002. Ps-S did not require an earlier transfer and sold the securities to F on Jan. 15, 2003. Ps treated the transaction as a securities lending arrangement subject to sec. 1058, I.R.C., and Ps-S reported an…
1Opinion of the Court
OPINION
Kroupa, Judge:
These consolidated cases are before the Court on petitioners’ motion for summary judgment and respondent’s cross-motion for partial summary judgment. Respondent determined a $2,177,532 deficiency for 2001 and a $171,026 deficiency for 2003 in the Federal income taxes of Henry and Susan F. Samueli (collectively, Samuelis). Respondent determined a $6,126 deficiency for 2001 in the Federal income tax of Thomas G. and Patricia W. Ricks (collectively, Rickses). Each deficiency relates to petitioners’ participation in a leveraged securities transaction (Transaction).1…
2Cases cited26 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Kawaauhau v. GeigerSupreme Court of the United States · 1998
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Associated Press v. United StatesSupreme Court of the United States · 1945
- Jacklin v. CommissionerUnited States Tax Court · 1982
21 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Calloway v. CommissionerUnited States Tax Court · 2010
- Samueli v. Comm'rUnited States Tax Court · 2009
- Lizzie W. Calloway v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2012
- Chapman Glen Ltd. v. CommissionerUnited States Tax Court · 2013
- Anschutz Co. v. CommissionerUnited States Tax Court · 2010
15 more not listed; retrieve them via the Exa API.