S. C. Johnson & Son, Inc. v. Commissioner
United States Tax Court
Petitioner entered into two forward sales contracts with respect to the British pound. After devaluation of the pound in November 1967, these contracts had substantially appreciated in value. Petitioner contributed the contracts to a charitable organization which subsequently entered into negotiations and sold the contracts to an unrelated third party. Held, petitioner did not realize income as a result of the contribution and subsequent sale of the forward sales contracts.
1Opinion of the Court
Featherston, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax as follows:
TYE Deficiency
June 30,1967 _ $2,037,317.76
June 28,1968 _ 2,768,400.26
Other issues having been settled, the only issue remaining for decision is whether petitioner realized unreported income in the amount of $555,427.50 from the contribution of two foreign exchange contracts to a charitable organization and the subsequent sale of those contracts by the charitable organization and, if so, whether the income realized on the sale of the contracts is taxable as ordinary gain or as capital gain.
FINDIN…
2Cases cited26 opinions
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Palmer v. CommissionerUnited States Tax Court · 1974
- Lawrence B. Sheppard and Charlotte N. Sheppard v. The United StatesUnited States Court of Claims · 1966
- Edwin W. Hudspeth and Maxine G. Hudspeth v. United StatesCourt of Appeals for the Eighth Circuit · 1972
- Humacid Co. v. CommissionerUnited States Tax Court · 1964
21 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Leonard Greene and Joyce Greene v. United StatesCourt of Appeals for the Second Circuit · 1994
- Rauenhorst v. Comm'rUnited States Tax Court · 2002
- Goodman v. CommissionerUnited States Tax Court · 1980
- Allen v. CommissionerUnited States Tax Court · 1976
- Carborundum Co. v. CommissionerUnited States Tax Court · 1980
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