Sheldon v. Comm'r
United States Tax Court
In November and December 1981, G, a limited partnership, purchased Treasury Bills (T-Bills) maturing in January 1982. G simultaneously entered into repurchase agreements (repos) involving the same T-Bills, with the same dealers who sold G the T-Bills. Under the terms of the repos, G sold the T-Bills to the dealers and promised to repurchase the T-Bills at future dates for the same prices plus stated interest.
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In November and December 1981, G, a limited partnership, purchased Treasury Bills (T-Bills) maturing in January 1982. G simultaneously entered into repurchase agreements (repos) involving the same T-Bills, with the same dealers who sold G the T-Bills. Under the terms of the repos, G sold the T-Bills to the dealers and promised to repurchase the T-Bills at future dates for the same prices plus stated interest. One of the repos, from its inception, was to close on the maturity date of the corresponding T-Bills (a repo to maturity). On the dates other repos were to close, G entered into new…
1Opinion of the Court
GERBER, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax in the amount of $56,133 and liability for the increased rate of interest under section 6621(c)1 for taxable year 1981. In an amended answer, respondent also asserted that petitioners are liable for the section 6653(a)(1) and (2) additions to tax for negligence or intentional disregard of rules and regulations. The issues for our consideration are (1) whether purchases of U.S. Treasury Bills financed by repurchase agreements were fictitious, (2) whether the transactions lacked economic substance, (3) whether…
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Neely v. CommissionerUnited States Tax Court · 1985
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
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3Cited by38 opinions
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- United States v. Victor Wexler, Honorable John W. Bissell, NominalCourt of Appeals for the Third Circuit · 1994
- Winn-Dixie Stores v. Comm'rUnited States Tax Court · 1999
- Compaq Computer Corp. v. CommissionerUnited States Tax Court · 1999
- Internal Revenue Service v. CM Holdings, Inc. (In Re CM Holdings, Inc.)District Court, D. Delaware · 2000
33 more not listed; retrieve them via the Exa API.