Hart v. Commissioner
United States Tax Court
On or about December 20, 1956, Federman, an employee of the firm which the petitioner principally used as his stockbroker, and who handled the petitioner's transactions with the firm, advised petitioner of a device whereby, in his opinion, the petitioner could obtain an income tax advantage by selling short a stock on which a large dividend arrearage had been declared, at a price which included the dividend, then pay the dividend to the broker, the amount of which would be…
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On or about December 20, 1956, Federman, an employee of the firm which the petitioner principally used as his stockbroker, and who handled the petitioner's transactions with the firm, advised petitioner of a device whereby, in his opinion, the petitioner could obtain an income tax advantage by selling short a stock on which a large dividend arrearage had been declared, at a price which included the dividend, then pay the dividend to the broker, the amount of which would be deductible from ordinary income in his income tax return, and then covering the short sale by purchasing the stock at a…
1Opinion of the Court
Milton Hart and Vivien Hart, Petitioners, v. Commissioner of Internal Revenue, Respondent
Hart v. Commissioner
Docket No. 203-62
United States Tax Court
41 T.C. 131; 1963 U.S. Tax Ct. LEXIS 30;
October 29, 1963, Filed
Decision will be entered for the respondent.
On or about December 20, 1956, Federman, an employee of the firm which the petitioner principally used as his stockbroker, and who handled the petitioner's transactions with the firm, advised petitioner of a device whereby, in his opinion, the petitioner could obtain an income tax advantage by selling short a stock on which a large dividend…
Also in this document: Concurrence.
2Cases cited9 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Empire Press, Inc. v. CommissionerUnited States Tax Court · 1960
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