Estate of McKelvey v. Comm'r
United States Tax Court
Decedent (D) entered into variable prepaid forward contracts (original VPFCs) with two investment banks in 2007. Pursuant to the terms of the original VPFCs, the investment banks made prepaid cash payments to D, and D was obligated to deliver variable quantities of stock to the investment banks on specified future settlement dates in 2008 (original settlement dates). D treated the execution of the original VPFCs as open transactions pursuant to Rev. Rul. 2003-7, 2003-1 C.B.…
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Decedent (D) entered into variable prepaid forward contracts (original VPFCs) with two investment banks in 2007. Pursuant to the terms of the original VPFCs, the investment banks made prepaid cash payments to D, and D was obligated to deliver variable quantities of stock to the investment banks on specified future settlement dates in 2008 (original settlement dates). D treated the execution of the original VPFCs as open transactions pursuant to Rev. Rul. 2003-7, 2003-1 C.B. 363, and did not report any gain or loss for 2007. In 2008, before the original settlement dates, D paid consideration…
1Opinion of the Court
ESTATE OF ANDREW J. MCKELVEY, DECEASED, BRADFORD G. PETERS, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of McKelvey v. Comm'r
Docket No. 26830-14
United States Tax Court
2017 U.S. Tax Ct. LEXIS 14; 148 T.C. No. 13;
April 19, 2017, Filed
Decision will be entered for petitioner.
Decedent (D) entered into variable prepaid forward contracts (original VPFCs) with two investment banks in 2007. Pursuant to the terms of the original VPFCs, the investment banks made prepaid cash payments to D, and D was obligated to deliver variable quantities of stock to the investment banks…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Watt v. AlaskaSupreme Court of the United States · 1981
- Edwards v. AguillardSupreme Court of the United States · 1987
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
16 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Estate of Andrew J. McKelvey v. Commr. of Internal RevenueCourt of Appeals for the Second Circuit · 2018