Mitchell v. Commissioner
United States Tax Court
P was employed as chairman and CEO of a thrift savings and loan, C. C was subject to the regulatory authority of the Federal Home Loan Bank Board (Bank Board). As part of 1987 yearend tax planning, C decided to sell certain stock in X in order to offset the capital losses against its capital gains. P arranged for an indirect sale of the X stock to himself. After completing the transaction and learning that it violated a Bank Board regulation, P so informed the Bank Board.
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P was employed as chairman and CEO of a thrift savings and loan, C. C was subject to the regulatory authority of the Federal Home Loan Bank Board (Bank Board). As part of 1987 yearend tax planning, C decided to sell certain stock in X in order to offset the capital losses against its capital gains. P arranged for an indirect sale of the X stock to himself. After completing the transaction and learning that it violated a Bank Board regulation, P so informed the Bank Board. C's auditor determined that C's expected capital loss from the sale of the X stock would be disallowed under sec. 267,…
1Opinion of the Court
LOUIS A. MITCHELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mitchell v. Commissioner
Docket No. 21097-92
United States Tax Court
T.C. Memo 1994-237; 1994 Tax Ct. Memo LEXIS 238; 67 T.C.M. (CCH) 3015;
May 26, 1994, Filed
P was employed as chairman and CEO of a thrift savings and loan, C. C was subject to the regulatory authority of the Federal Home Loan Bank Board (Bank Board).
As part of 1987 yearend tax planning, C decided to sell certain stock in X in order to offset the capital losses against its capital gains. P arranged for an indirect sale of the X stock to himself. After…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Schirmer v. CommissionerUnited States Tax Court · 1987
- Gould v. CommissionerUnited States Tax Court · 1975
- Pike v. CommissionerUnited States Tax Court · 1965
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