Price v. Commissioner
United States Tax Court
Various partnerships (Newcomb Government Securities, Price & Co., and Magna & Co.) controlled by petitioners traded in Government securities. The partnerships engaged in prearranged straddle transactions involving Treasury bills and notes with dealers (dealer transactions) which produced losses to the partnerships.
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Various partnerships (Newcomb Government Securities, Price & Co., and Magna & Co.) controlled by petitioners traded in Government securities. The partnerships engaged in prearranged straddle transactions involving Treasury bills and notes with dealers (dealer transactions) which produced losses to the partnerships. With respect to one of the partnerships (Newcomb Government Securities), corresponding trades were with its customers (Newcomb customer transactions) which produced gains to the partnership. Petitioners deducted their distributive share of partnership trading losses, fees, and…
1Opinion of the Court
JACOBS, Judge:
Respondent determined the following deficiencies in income tax and additions to tax:
Docket No. Year Petitioners Addition to tax Deficiency sec. 6653(b)3
26907-83 1978 E. Lawrence and Elaine Price $67,717 $33,921
5647-83 1979 E. Lawrence and Elaine Price 3,081,827 1,540,913
35838-83 1979 Lonnie E. and Steffie Price 337,867 168,933
In his answers to the petitions filed in this case, and amendments thereto, respondent claimed increased deficiencies and additions to tax, as follows:
Docket No. Increased deficiency Increased addition to tax
26907-83 $193,394 $96,760
35647-83 35,973,948…
2Cases cited20 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Stone v. CommissionerUnited States Tax Court · 1971
- Gajewski v. CommissionerUnited States Tax Court · 1976
15 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Freytag v. CommissionerUnited States Tax Court · 1987
- James C. Thomas, as Trustee of Slt Trust 1 (Rev): 9/29/83 v. E. Lawrence Price, as Trustee of the Elaine Price Trust 1983Court of Appeals for the Fifth Circuit · 1992
- Ernest P. Kline v. First Western Government Securities, Inc.Court of Appeals for the First Circuit · 1994
- Sheldon v. Comm'rUnited States Tax Court · 1990
- Saltzman v. CommissionerUnited States Tax Court · 1970
27 more not listed; retrieve them via the Exa API.