Wool Distributing Corp. v. Commissioner
United States Tax Court
During the period October 1951 to October 1952 the petitioner, an international wool dealer, carried large quantities of sterling area and French wools in inventory. Throughout the same period rumors that the pound sterling and French franc would be devalued were widespread.
Read the full summary
During the period October 1951 to October 1952 the petitioner, an international wool dealer, carried large quantities of sterling area and French wools in inventory. Throughout the same period rumors that the pound sterling and French franc would be devalued were widespread. Fearing that devaluation of these currencies would bring about an immediate decline in the market value of its foreign wool inventory, the petitioner sold pounds sterling and French francs short in amounts not in excess of its holdings of sterling area and French wools. Held, under these specific and unusual circumstances…
1Opinion of the Court
OPINION.
Keen, Judge:
The question to be decided in this proceeding is whether the net losses that petitioner sustained during the taxable year as the result of its dealings in pound sterling and French franc futures are ordinary losses deductible in full from gross income or, as respondent has determined, capital losses allowable only to the extent of offsetting capital gains of which petitioner had none because such futures were capital assets within the meaning of section 117 of the Internal Revenue Code of 1939.2 The question is essentially one of fact.
It is apparent from the contentions of…
2Cases cited6 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- United States v. Security Trust & Savings BankSupreme Court of the United States · 1950
- Commissioner of Internal Rev. v. Farmers & G C. Oil Co.Court of Appeals for the Fifth Circuit · 1941
- America-Southeast Asia Co. v. CommissionerUnited States Tax Court · 1956
- Farmers & Ginners Cotton Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1940
1 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- National-Standard Co. v. CommissionerUnited States Tax Court · 1983
- Hoover Co. v. CommissionerUnited States Tax Court · 1979
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Kentucky & Indiana Terminal Railroad Company v. United StatesCourt of Appeals for the Sixth Circuit · 1964
- American Home Products Corp. v. United StatesUnited States Court of Claims · 1979
6 more not listed; retrieve them via the Exa API.