Legal Opinion

Wolff v. Commissioner

United States Tax Court

Decided May 2, 1994No. Docket No. 13142-89Unpublished

In Stoller v. Commissioner, T.C. Memo. 1990-659, affd. in part and revd. in part 994 F.2d 855 (D.C. Cir. 1993), we held that S, a partner in Holly, was not entitled to ordinary loss treatment with respect to the cancellation and replacement of certain forward contracts. The Court of Appeals held that S properly claimed an ordinary loss from the cancellation and replacement of the forward contracts.

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In Stoller v. Commissioner, T.C. Memo. 1990-659, affd. in part and revd. in part 994 F.2d 855 (D.C. Cir. 1993), we held that S, a partner in Holly, was not entitled to ordinary loss treatment with respect to the cancellation and replacement of certain forward contracts. The Court of Appeals held that S properly claimed an ordinary loss from the cancellation and replacement of the forward contracts. R determined in this proceeding that P, also a partner in Holly, is not entitled to ordinary loss treatment with respect to the cancellation and replacement of those same forward contracts. P filed…

1Opinion of the Court

JONATHAN P. WOLFF AND MARGARET A. WOLFF, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Wolff v. Commissioner

Docket No. 13142-89

United States Tax Court

T.C. Memo 1994-196; 1994 Tax Ct. Memo LEXIS 198; 67 T.C.M. (CCH) 2875; T.C.M. (RIA) 94196;

May 2, 1994, Filed

An order will be issued denying petitioners' motion for summary judgment.

In Stoller v. Commissioner, T.C. Memo. 1990-659, affd. in part and revd. in part 994 F.2d 855 (D.C. Cir. 1993), we held that S, a partner in Holly, was not entitled to ordinary loss treatment with respect to the cancellation and replacement of certain…

2Cases cited29 opinions

  1. Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
  2. Montana v. United StatesSupreme Court of the United States · 1979
  3. Commissioner v. SunnenSupreme Court of the United States · 1948
  4. Blonder-Tongue Laboratories, Inc. v. University of Illinois FoundationSupreme Court of the United States · 1971
  5. United States v. MendozaSupreme Court of the United States · 1984

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