Estate of Israel v. Commissioner
United States Tax Court
Held: Fees paid in connection with "cancellation" of legs of commodity forward contracts treated as capital losses, not ordinary losses. The opinion of the U.S. Court of Appeals for the District of Columbia Circuit in Stoller v. Commissioner, 994 F.2d 855 (D.C.
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Held: Fees paid in connection with "cancellation" of legs of commodity forward contracts treated as capital losses, not ordinary losses. The opinion of the U.S. Court of Appeals for the District of Columbia Circuit in Stoller v. Commissioner, 994 F.2d 855 (D.C. Cir. 1993) (in its treatment of losses from cancellation and replacement, and cancellation and termination, of legs of commodity forward contracts as ordinary losses) not followed, and our opinion in Stoller v. Commissioner, T.C. Memo. 1990-659, affd. in part and revd. in part 994 F.2d 855 (D.C. Cir. 1993) (in its treatment of losses…
1Opinion of the Court
ESTATE OF LEON ISRAEL, JR., DECEASED, BARRY W. GRAY, EXECUTOR, AND AUDREY H. ISRAEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; JONATHAN P. WOLFF AND MARGARET A. WOLFF, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Israel v. Commissioner
Docket Nos. 31588-88, 13142-89
United States Tax Court
108 T.C. 208; 1997 U.S. Tax Ct. LEXIS 12; 108 T.C. No. 13;
April 1, 1997, Filed
Decisions will be entered under Rule 155.
Held: Fees paid in connection with "cancellation" of legs of commodity forward contracts treated as capital losses, not ordinary losses. The opinion…
Also in this document: Concurrence; Dissent.
2Cases cited42 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Board of Trade of Chicago v. Christie Grain & Stock Co.Supreme Court of the United States · 1905
- James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
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