Legal Opinion

Estate of Israel v. Commissioner

United States Tax Court

Decided April 1, 1997No. Docket Nos. 31588-88, 13142-89Published

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

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  3. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  4. Board of Trade of Chicago v. Christie Grain & Stock Co.Supreme Court of the United States · 1905
  5. 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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