Legal Opinion

Durrett v. Commissioner

United States Tax Court

Decided April 21, 1994No. Docket No. 21771-84UnpublishedCited by 5 opinions

The notice of deficiency in this case involving the taxable years 1979, 1980, and 1981 was mailed to Ps on April 3, 1984. The deficiencies resulted primarily from the disallowances of losses claimed with regard to straddle transactions with First Western Government Securities, Inc. This Court sustained the disallowance of similar losses in Freytag v. Commissioner, 89 T.C. 849 (1987), affd. 904 F.2d 1011 (5th Cir. 1990), affd. on other grounds 501 U.S. , 111 S. Ct. 2631…

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The notice of deficiency in this case involving the taxable years 1979, 1980, and 1981 was mailed to Ps on April 3, 1984. The deficiencies resulted primarily from the disallowances of losses claimed with regard to straddle transactions with First Western Government Securities, Inc. This Court sustained the disallowance of similar losses in Freytag v. Commissioner, 89 T.C. 849 (1987), affd. 904 F.2d 1011 (5th Cir. 1990), affd. on other grounds 501 U.S. , 111 S. Ct. 2631 (1991). Ps do not dispute the deficiencies and concede that the transactions involved here are indistinguishable from those…

1Opinion of the Court

JOSEPH B. DURRETT, JR. AND CAROLYN C. DURRETT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

Durrett v. Commissioner

Docket No. 21771-84

United States Tax Court

T.C. Memo 1994-179; 1994 Tax Ct. Memo LEXIS 179; 67 T.C.M. (CCH) 2735;

April 21, 1994, Filed

An appropriate order will be issued denying petitioners' motion for leave to amend petition and decision will be entered under Rule 155.

The notice of deficiency in this case involving the taxable years 1979, 1980, and 1981 was mailed to Ps on April 3, 1984. The deficiencies resulted primarily from the disallowances of losses claimed…

2Cases cited33 opinions

  1. Freytag v. CommissionerSupreme Court of the United States · 1991
  2. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  3. George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
  4. Freytag v. CommissionerUnited States Tax Court · 1987
  5. Zmuda v. CommissionerUnited States Tax Court · 1982

28 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Olson v. United StatesUnited States Court of Federal Claims · 1997
  2. Allison v. United StatesUnited States Court of Federal Claims · 2008
  3. Weiner v. United StatesDistrict Court, S.D. Texas · 2002
  4. Foulds v. CommissionerUnited States Tax Court · 1994
  5. Hunt v. CommissionerUnited States Tax Court · 2001

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