Currie v. Commissioner
United States Tax Court
The petitioners were members of a syndicate formed in mid-1962 for the purpose of acquiring, holding, and eventually selling at a profit 51 percent of the common stock of a stock and mutual life insurance company. At that time, the syndicate acquired from another syndicate (of which petitioners were also members) an option to buy the stock.
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The petitioners were members of a syndicate formed in mid-1962 for the purpose of acquiring, holding, and eventually selling at a profit 51 percent of the common stock of a stock and mutual life insurance company. At that time, the syndicate acquired from another syndicate (of which petitioners were also members) an option to buy the stock. Both syndicates were organized and controlled by an individual active in the securities business who was a specialist in the field of insurance securities. The second syndicate immediately exercised the option and purchased the stock. In mid-1963, over 6…
1Opinion of the Court
Francis C. Currie and Eleanor B. Currie, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Currie v. Commissioner
Docket Nos. 3190-67, 3226-67, 3227-67
United States Tax Court
53 T.C. 185; 1969 U.S. Tax Ct. LEXIS 28;
November 10, 1969, Filed
Decisions will be entered for the petitioners.
The petitioners were members of a syndicate formed in mid-1962 for the purpose of acquiring, holding, and eventually selling at a profit 51 percent of the common stock of a stock and mutual life insurance company. At that time, the syndicate acquired from another syndicate (of which petitioners…
2Cases cited13 opinions
- Schafer v. HelveringSupreme Court of the United States · 1936
- Estate of Freeland v. CommissionerCourt of Appeals for the Ninth Circuit · 1968
- Van Suetendael v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Second Circuit · 1945
- Mirro-Dynamics Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1967
- Commissioner of Internal Revenue v. CharavayCourt of Appeals for the Third Circuit · 1935
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