Legal Opinion

International Flavors & Fragrances, Inc. v. Commissioner

United States Tax Court

Decided May 16, 1974No. Docket No. 7768-70Published

Petitioner and its foreign affiliates are engaged worldwide in the manufacture and distribution of flavoring extracts. In order to offset any loss which might be sustained in event of the devaluation of the British pound sterling, petitioner entered into a short sale contract for pounds sterling. After the pound was devalued, but before the delivery date, petitioner either sold or closed out its contract.

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Petitioner and its foreign affiliates are engaged worldwide in the manufacture and distribution of flavoring extracts. In order to offset any loss which might be sustained in event of the devaluation of the British pound sterling, petitioner entered into a short sale contract for pounds sterling. After the pound was devalued, but before the delivery date, petitioner either sold or closed out its contract. Held, the gain to petitioner on the transaction is taxable as ordinary income under the principles of Corn Products Co. v. Commissioner, 350 U.S. 46 (1955).

1Opinion of the Court

International Flavors & Fragrances Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

International Flavors & Fragrances, Inc. v. Commissioner

Docket No. 7768-70

United States Tax Court

62 T.C. 232; 1974 U.S. Tax Ct. LEXIS 104; 62 T.C. No. 26;

May 16, 1974, Filed

Decision will be entered under Rule 155.

Petitioner and its foreign affiliates are engaged worldwide in the manufacture and distribution of flavoring extracts. In order to offset any loss which might be sustained in event of the devaluation of the British pound sterling, petitioner entered into a short sale contract for pounds…

Also in this document: Concurrence.

2Cases cited32 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  4. Commissioner v. BrownSupreme Court of the United States · 1965
  5. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949

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