Sicanoff Vegetable Oil Corporation v. Commissioner of Internal Revenue, Sicanoff Tallow Corporation v. Commissioner of Internal Revenue

HASTINGS, Circuit Judge.

Petitioners, Sicanoff Vegetable Oil Corporation and Sicanoff Tallow Corporation, appeal from a decision of the Tax Court of the United States which sustained the Commissioner of Internal Revenue’s determination that 80% of their gross income for 1950 consisted of gains from futures transactions in commodities subject to the rules of a board of trade or commodity exchange, none of which gains resulted from bona fide hedging transactions reasonably necessary in the conduct of their business, and that, therefore, both were personal holding companies as defined by the…