Legal Opinion
Stephen A. Mahoney, Iii, and Mary Ann Mahoney v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided January 14, 1987No. 86-1131PublishedCited by 83 opinions
1Opinion of the Court
RALPH B. GUY, Jr., Circuit Judge.
This is a complicated case involving gold and platinum straddles on the London market. Although we are dealing with only one appellant, the case was actually a consolidated trial at the Tax Court level, involving several different persons similarly situated.
The issue in the case is the deductibility of the tax losses sustained by all the taxpayers who entered into these straddles. Such transactions, in order to be deductible under the Internal Revenue Code, have to have been transactions “entered into for profit.” 1 Although the Code phrase is a term of art…
2Cases cited3 opinions
- Smith v. CommissionerUnited States Tax Court · 1982
- Leahy v. CommissionerUnited States Tax Court · 1986
- Wooldridge v. Comr. Of I.R.SCourt of Appeals for the Eleventh Circuit · 1986
3Cited by83 opinions
- Freytag v. CommissionerUnited States Tax Court · 1987
- James L. Rose and Judy S. Rose v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Kenneth P. Kirchman and Budagail S. Kirchman, Leo P. Ayotte and Nancy C. Ayotte v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1989
- Ewing v. CommissionerUnited States Tax Court · 1988
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