Henry and Susan F. Samueli v. Commissioner

132 T.C. No. 4

UNITED STATES TAX COURT HENRY AND SUSAN F. SAMUELI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent THOMAS G. AND PATRICIA W. RICKS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 13953-06, 14147-06. Filed March 16, 2009. Ps-S purchased an approximate $1.64 billion of securities from F in October 2001 and simultaneously transferred the securities back to F pursuant to F’s promise to transfer identical securities to Ps-S on Jan. 15, 2003. The agreement between Ps-S and F allowed Ps-S to require an earlier transfer of the identical securities…