Kurtin v. Commissioner
United States Tax Court
Losses on sales of butter futures entered into to protect taxpayers against decline in the price of cheese purchased under forward contracts at a fixed price, held, on the facts, to be allowable in full as hedging transactions.
1Opinion of the Court
OPINION.
OppeR, Jvdge:
That the butter futures contracts closed out by petitioner at a loss were hedges within the meaning of G. C. M. 173221 and the cases applying it seems to us inescapable both as a factual and as a legal conclusion. The commitment as to which petitioner sought to insure himself against loss was his purchase of certain types of cheese for future delivery. His agreements with the producers required him several months later to accept the product at the previously stipulated price.
The uncontradicted testimony was that there is no futures market for cheese but that the price of…
2Cases cited3 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Trenton Cotton Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1945
- Corn Products Refining Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
3Cited by11 opinions
- Sicanoff Vegetable Oil Corp. v. CommissionerUnited States Tax Court · 1957
- Wool Distributing Corp. v. CommissionerUnited States Tax Court · 1960
- Oxford Paper Co. v. CommissionerUnited States Tax Court · 1960
- Myers v. CommissionerUnited States Tax Court · 1986
- Kurtin v. CommissionerUnited States Tax Court · 1956
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