Smith v. Commissioner
United States Tax Court
On Aug. 7, 1973, petitioners S and J each acquired long positions in 21 March 1974 silver futures contracts and 21 December 1974 silver futures contracts and short positions in 42 July 1974 silver futures contracts pursuant to simultaneously placed "straddle" trades complying with the rules of the Commodity Exchange, Inc. (COMEX). Two days later, on Aug. 9, 1973, petitioners, respectively, acquired long positions in 21 May 1974 silver futures contracts and 21 September 1974…
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On Aug. 7, 1973, petitioners S and J each acquired long positions in 21 March 1974 silver futures contracts and 21 December 1974 silver futures contracts and short positions in 42 July 1974 silver futures contracts pursuant to simultaneously placed "straddle" trades complying with the rules of the Commodity Exchange, Inc. (COMEX). Two days later, on Aug. 9, 1973, petitioners, respectively, acquired long positions in 21 May 1974 silver futures contracts and 21 September 1974 silver futures contracts and short positions in 21 March 1974 silver futures contracts and 21 December 1974 silver…
1Opinion of the Court
Nims, Judge:
In these consolidated cases, respondent determined the following deficiencies in petitioners’ Federal income taxes for the taxable year 1973:
Docket No. Petitioner Deficiency
12709-77 Harry Lee Smith and Patricia Ann Smith $27,541
185-78 Herbert J. Jacobson and Ruth D. Jacobson 30,196
Concessions having been made by petitioners in docket No. 12709-77, the sole issue remaining for decision is the deducti-bility of certain losses claimed by petitioners to have resulted from engaging in what is commonly referred to as a "commodity tax straddle.”
FINDINGS OF FACT
Some of the facts have been…
2Cases cited40 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- United States v. Norman TurkishCourt of Appeals for the Second Circuit · 1980
35 more not listed; retrieve them via the Exa API.
3Cited by99 opinions
- Freytag v. CommissionerUnited States Tax Court · 1987
- Glass v. CommissionerUnited States Tax Court · 1986
- Ewing v. CommissionerUnited States Tax Court · 1988
- Brown v. CommissionerUnited States Tax Court · 1985
- Fox v. CommissionerUnited States Tax Court · 1984
94 more not listed; retrieve them via the Exa API.