S. C. Johnson & Son, Inc. v. Commissioner
United States Tax Court
Petitioner entered into two forward sales contracts with respect to the British pound. After devaluation of the pound in November 1967, these contracts had substantially appreciated in value. Petitioner contributed the contracts to a charitable organization which subsequently entered into negotiations and sold the contracts to an unrelated third party. Held, petitioner did not realize income as a result of the contribution and subsequent sale of the forward sales contracts.
1Opinion of the Court
S. C. Johnson & Son, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
S. C. Johnson & Son, Inc. v. Commissioner
Docket No. 1821-72
United States Tax Court
63 T.C. 778; 1975 U.S. Tax Ct. LEXIS 172;
March 31, 1975, Filed
Decision will be entered under Rule 155.
Petitioner entered into two forward sales contracts with respect to the British pound. After devaluation of the pound in November 1967, these contracts had substantially appreciated in value. Petitioner contributed the contracts to a charitable organization which subsequently entered into negotiations and sold the contracts to…
2Cases cited28 opinions
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Palmer v. CommissionerUnited States Tax Court · 1974
- Lawrence B. Sheppard and Charlotte N. Sheppard v. The United StatesUnited States Court of Claims · 1966
- Edwin W. Hudspeth and Maxine G. Hudspeth v. United StatesCourt of Appeals for the Eighth Circuit · 1972
- Humacid Co. v. CommissionerUnited States Tax Court · 1964
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