Legal Opinion
Commissioner of Internal Revenue v. Covington
Court of Appeals for the Fifth Circuit
Decided June 9, 1941No. 9806PublishedCited by 54 opinions
1Opinion of the Court
HUTCHESON, Circuit Judge.
The Board of Tax Appeals decided (1) that Commodity Futures Trading losses incurred in the years 1936 and 1937, were capital losses and subject to the $2,000 limitation of Section 117 (d), Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Acts, page 875, and (2) that commissions paid in connection with such trades were deductible but only to the extent that they are attributable to sales. The taxpayer is here complaining of the first ruling, and both taxpayer and commissioner are here complaining of the second. The commissioner complains because any commissions were allowed,…
2Cases cited6 opinions
- Helvering v. WinmillSupreme Court of the United States · 1938
- Board of Trade of Chicago v. Christie Grain & Stock Co.Supreme Court of the United States · 1905
- United States v. New York Coffee & Sugar Exchange, Inc.Supreme Court of the United States · 1924
- Neuberger v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1939
- Winmill v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1937
1 more not listed; retrieve them via the Exa API.
3Cited by54 opinions
- Smith v. CommissionerUnited States Tax Court · 1982
- Spreckels v. CommissionerSupreme Court of the United States · 1942
- Polachek v. CommissionerUnited States Tax Court · 1954
- Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- King v. CommissionerUnited States Tax Court · 1987
49 more not listed; retrieve them via the Exa API.