Legal Opinion
Douglas J. Michelson v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided December 18, 1991No. 90-9020PublishedCited by 8 opinions
1Opinion of the Court
BRORBY, Circuit Judge.
Mr. Michelson appeals from the decisions of the United States Tax Court entered July 26, 1990, determining deficiencies in his federal income tax for the years 1976-81. We affirm those decisions.
The issues in this case derive from the financial losses Mr. Michelson sustained as a result of his transactions involving metal futures (primarily silver) on various commodity exchanges. Characterization of Mr. Michelson’s losses was the principal issue before the tax court. Mr. Michelson asserts he was a dealer in metals. As such, he contends the losses resulting from his 1979…
2Cases cited5 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Stanley L. Boren, Shirley Boren v. Donald Sable, Sr. And Donald Sable, IICourt of Appeals for the Tenth Circuit · 1989
- Sanchez v. BondCourt of Appeals for the Tenth Circuit · 1989
- The Merchants National Bank of Topeka v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1977
- Michelson v. CommissionerUnited States Tax Court · 1990
3Cited by8 opinions
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Bielfeldt v. CommissionerUnited States Tax Court · 1998
- Douglas J. Michelson v. United States of America, Internal Revenue Service, United New Mexico Bank at Albuquerque, John Doe, GarnisheesCourt of Appeals for the Tenth Circuit · 1994
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Furer v. CommissionerUnited States Tax Court · 1993
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