Legal Opinion
Terence J. Horn and Jean Horn v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Terence J. Horn and Jean Horn
Court of Appeals for the D.C. Circuit
Decided June 26, 1992No. 91-1201, 91-1359PublishedCited by 41 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge HARRY T. EDWARDS.
HARRY T. EDWARDS, Circuit Judge:
In this case, we are called upon to decide whether Congress intended to authorize a deduction for losses incurred by certain taxpayers who engaged in transactions of a type designed to secure tax benefits while avoiding any economic risk. More specifically, we must decide whether section 108 of the Tax Reform Act of 1984, as amended, permits commodities dealers to deduct losses incurred in the disposition of the legs of straddle transactions, even if the taxpayer’s pattern of trading reveals that the…
2Cases cited22 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- Glass v. CommissionerUnited States Tax Court · 1986
17 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Rogers v. United StatesCourt of Appeals for the Tenth Circuit · 2002
- Wal-Mart Stores, Inc. v. AIG Life InsuranceCourt of Chancery of Delaware · 2005
- TD Banknorth, N.A. v. Department of TaxesSupreme Court of Vermont · 2008
- Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. CommissionerUnited States Tax Court · 2012
- Internal Revenue Service v. CM Holdings, Inc. (In Re CM Holdings, Inc.)District Court, D. Delaware · 2000
36 more not listed; retrieve them via the Exa API.