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