Gantner v. Commissioner
United States Tax Court
Held, losses on sales of stock options are not subject to disallowance as wash-sales pursuant to sec. 1091, I.R.C. 1954, because options are not "stock or securities" within the meaning of sec. 1091. Held, P is not entitled to deductions and investment credits relating to computers used by his employer, a corporation in which P is a 50-percent shareholder. Held, P is not entitled to deductions for a home office and other expenses.
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Held, losses on sales of stock options are not subject to disallowance as wash-sales pursuant to sec. 1091, I.R.C. 1954, because options are not "stock or securities" within the meaning of sec. 1091. Held, P is not entitled to deductions and investment credits relating to computers used by his employer, a corporation in which P is a 50-percent shareholder. Held, P is not entitled to deductions for a home office and other expenses. Held, regardless of the date of assessment, P is liable for increased interest pursuant to sec. 6621(c) because a substantial underpayment of taxes attributable to…
1Opinion of the Court
David E. and Sandra L. Gantner, Petitioners v. Commissioner of Internal Revenue, Respondent
Gantner v. Commissioner
Docket No. 2222-86
United States Tax Court
91 T.C. 713; 1988 U.S. Tax Ct. LEXIS 125; 91 T.C. No. 47;
September 29, 1988September 29, 1988, Filed
Decision will be entered under Rule 155.
Held, losses on sales of stock options are not subject to disallowance as wash-sales pursuant to sec. 1091, I.R.C. 1954, because options are not "stock or securities" within the meaning of sec. 1091. Held, P is not entitled to deductions and investment credits relating to computers used by his employer,…
2Cases cited37 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
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