Domulewicz v. Comm'r
United States Tax Court
As part of a Son-of-BOSS transaction designed to create a basis of approximately $ 29.3 million in publicly traded stock purchased at a relatively minimal cost, P entered into a short sale of U.S. Treasury notes and contributed the proceeds of that sale and the related obligation to a partnership (DIP) in which P was one of three partners.
Read the full summary
As part of a Son-of-BOSS transaction designed to create a basis of approximately $ 29.3 million in publicly traded stock purchased at a relatively minimal cost, P entered into a short sale of U.S. Treasury notes and contributed the proceeds of that sale and the related obligation to a partnership (DIP) in which P was one of three partners. Neither P nor DIP treated the obligation assumed by DIP as a liability under sec. 752, I.R.C., and P did not compute his basis in DIP by taking the obligation into account. After DIP satisfied the obligation and received contributions of the publicly traded…
1Opinion of the Court
MICHAEL V. DOMULEWICZ AND MARY ANN DOMULEWICZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Domulewicz v. Comm'r
No. 10434-05
United States Tax Court
129 T.C. 11; 2007 U.S. Tax Ct. LEXIS 21; 129 T.C. No. 3;
August 8, 2007, Filed
As part of a Son-of-BOSS transaction designed to create a basis of approximately $ 29.3 million in publicly traded stock purchased at a relatively minimal cost, P entered into a short sale of U.S. Treasury notes and contributed the proceeds of that sale and the related obligation to a partnership (DIP) in which P was one of three partners. Neither P nor DIP…
2Cases cited21 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Day v. McDonoughSupreme Court of the United States · 2006
- Arlington Central School District Board of Education v. MurphySupreme Court of the United States · 2006
- Takao Ozawa v. United StatesSupreme Court of the United States · 1922
16 more not listed; retrieve them via the Exa API.