Heggestad v. Commissioner
United States Tax Court
P was a partner in a commodities brokerage firm. The partnership earned commissions for its services in effectuating customers' transactions in commodities futures. P also invested in commodities futures for his own account. In 1979 and 1980, P paid the partnership commissions in connection with commodities futures transactions for his personal account. Held: Certain losses incurred by P on the sale of Treasury bill futures contracts were capital, and not ordinary, losses.
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P was a partner in a commodities brokerage firm. The partnership earned commissions for its services in effectuating customers' transactions in commodities futures. P also invested in commodities futures for his own account. In 1979 and 1980, P paid the partnership commissions in connection with commodities futures transactions for his personal account. Held: Certain losses incurred by P on the sale of Treasury bill futures contracts were capital, and not ordinary, losses. P was not entitled to ordinary loss treatment under Corn Products Refining Co. v. Commissioner, 350 U.S. 46 (1955). Held,…
1Opinion of the Court
Gerald A. Heggestad and Cheryl L. Heggestad, Petitioners v. Commissioner of Internal Revenue, Respondent
Heggestad v. Commissioner
Docket No. 18265-84
United States Tax Court
91 T.C. 778; 1988 U.S. Tax Ct. LEXIS 132; 91 T.C. No. 50;
October 17, 1988; As amended October 19, 1988; As amended October 25, 1988 October 17, 1988, Filed
Decision will be entered under Rule 155.
P was a partner in a commodities brokerage firm. The partnership earned commissions for its services in effectuating customers' transactions in commodities futures. P also invested in commodities futures for his own account. In 1979…
2Cases cited16 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Neuberger v. CommissionerSupreme Court of the United States · 1940
- Booth Newspapers, Inc. v. The United States. The Evening News Association v. The United StatesUnited States Court of Claims · 1962
- W. W. Windle Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1977
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