Samueli v. Comm'r
United States Tax Court
Ps-S purchased an approximate $ 1.64 billion of securities from F in October 2001 and simultaneously transferred the securities back to F pursuant to F's promise to transfer identical securities to Ps-S on Jan. 15, 2003. The agreement between Ps-S and F allowed Ps-S to require an earlier transfer of the identical securities only by terminating the transaction on July 1 or Dec. 2, 2002. Ps-S did not require an earlier transfer and sold the securities to F on Jan. 15, 2003. Ps…
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Ps-S purchased an approximate $ 1.64 billion of securities from F in October 2001 and simultaneously transferred the securities back to F pursuant to F's promise to transfer identical securities to Ps-S on Jan. 15, 2003. The agreement between Ps-S and F allowed Ps-S to require an earlier transfer of the identical securities only by terminating the transaction on July 1 or Dec. 2, 2002. Ps-S did not require an earlier transfer and sold the securities to F on Jan. 15, 2003. Ps treated the transaction as a securities lending arrangement subject to sec. 1058, I.R.C., and Ps-S reported an…
1Opinion of the Court
HENRY AND SUSAN F. SAMUELI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Samueli v. Comm'r
Nos. 13953-06, 14147-06
United States Tax Court
132 T.C. 37; 2009 U.S. Tax Ct. LEXIS 4; 132 T.C. No. 4;
March 16, 2009, Filed
Ps-S purchased an approximate $ 1.64 billion of securities from F in October 2001 and simultaneously transferred the securities back to F pursuant to F's promise to transfer identical securities to Ps-S on Jan. 15, 2003. The agreement between Ps-S and F allowed Ps-S to require an earlier transfer of the identical securities only by terminating the transaction on July 1…
2Cases cited28 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Kawaauhau v. GeigerSupreme Court of the United States · 1998
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Associated Press v. United StatesSupreme Court of the United States · 1945
- Associated Press v. United StatesSupreme Court of the United States · 1945
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