Legal Opinion

The Board of Trade of the City of Chicago and Subsidiaries v. Commissioner

United States Tax Court

Decided May 29, 1996No. 8202-93Unknown

1Opinion of the Court

106 T.C. No. 21

UNITED STATES TAX COURT THE BOARD OF TRADE OF THE CITY OF CHICAGO AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8202-93. Filed May 29, 1996. Petitioner (P) is a taxable membership corporation that operates a futures exchange. When a membership on the exchange is transferred, the transferee must pay P a transfer fee, which, under P’s bylaws, is to be used to “purchase, retire or redeem the indebtedness encumbering the Board of Trade Building”, which houses P’s trading floor and substantial office space leased to third-party tenants.…

2Cases cited30 opinions

  1. Freuler v. HelveringSupreme Court of the United States · 1934
  2. General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
  3. City of New York v. SaperSupreme Court of the United States · 1949
  4. Recklitis v. CommissionerUnited States Tax Court · 1988
  5. Stark v. CommissionerUnited States Tax Court · 1986

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