Legal Opinion

Sheldon v. Comm'r

United States Tax Court

Decided May 29, 1990No. Docket No. 18208-85Published

In November and December 1981, G, a limited partnership, purchased Treasury Bills (T-Bills) maturing in January 1982. G simultaneously entered into repurchase agreements (repos) involving the same T-Bills, with the same dealers who sold G the T-Bills. Under the terms of the repos, G sold the T-Bills to the dealers and promised to repurchase the T-Bills at future dates for the same prices plus stated interest.

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In November and December 1981, G, a limited partnership, purchased Treasury Bills (T-Bills) maturing in January 1982. G simultaneously entered into repurchase agreements (repos) involving the same T-Bills, with the same dealers who sold G the T-Bills. Under the terms of the repos, G sold the T-Bills to the dealers and promised to repurchase the T-Bills at future dates for the same prices plus stated interest. One of the repos, from its inception, was to close on the maturity date of the corresponding T-Bills (a repo to maturity). On the dates other repos were to close, G entered into new…

1Opinion of the Court

Steven R. Sheldon and Ellen G. Sheldon, Petitioners v. Commissioner of Internal Revenue, Respondent

Sheldon v. Comm'r

Docket No. 18208-85

United States Tax Court

94 T.C. 738; 1990 U.S. Tax Ct. LEXIS 52; 94 T.C. No. 46;

May 29, 1990, Filed

Decision will be entered under Rule 155.

In November and December 1981, G, a limited partnership, purchased Treasury Bills (T-Bills) maturing in January 1982. G simultaneously entered into repurchase agreements (repos) involving the same T-Bills, with the same dealers who sold G the T-Bills. Under the terms of the repos, G sold the T-Bills to the dealers and…

Also in this document: Concurring in part, dissenting in part.

2Cases cited44 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Neely v. CommissionerUnited States Tax Court · 1985
  3. Knetsch v. United StatesSupreme Court of the United States · 1960
  4. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  5. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958

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