Sheldon v. Comm'r
United States Tax Court
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
- Gregory v. HelveringSupreme Court of the United States · 1935
- Neely v. CommissionerUnited States Tax Court · 1985
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
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