Legal Opinion

Carl Marks & Co. v. Commissioner

United States Tax Court

Decided June 30, 1949No. Docket No. 15187Published

Petitioner, a dealer in foreign securities, transferred all of its domestic securities and certain of its foreign securities out of its inventory to an investment account on December 29, 1941. Held, that the securities so transferred were thereafter held for speculative or investment purposes only and that the profits from the sale of the securities involved are taxable in accordance with sections 117 and 711 (a) (1) (B) of the Internal Revenue Code.

1Opinion of the Court

Carl Marks & Co., Petitioner, v. Commissioner of Internal Revenue, Respondent

Carl Marks & Co. v. Commissioner

Docket No. 15187

United States Tax Court

12 T.C. 1196; 1949 U.S. Tax Ct. LEXIS 140;

June 30, 1949, Promulgated

Decision will be entered under Rule 50.

Petitioner, a dealer in foreign securities, transferred all of its domestic securities and certain of its foreign securities out of its inventory to an investment account on December 29, 1941. Held, that the securities so transferred were thereafter held for speculative or investment purposes only and that the profits from the sale of the…

2Cases cited2 opinions

  1. Schafer v. HelveringSupreme Court of the United States · 1936
  2. Carl Marks & Co. v. CommissionerUnited States Tax Court · 1949

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