Legal Opinion

Starr v. Commissioner

United States Tax Court

Decided December 10, 1991No. Docket No. 39314-84UnpublishedCited by 1 opinion

Petitioner Erwin Starr, a retired businessman and an active investor, engaged in six series of futures straddles during 1978-80. Those straddles gave rise to short-term and long-term capital losses and gains, which were reported on petitioners' 1978, 1979, and 1980 tax returns. Respondent disallowed those gains and losses.

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Petitioner Erwin Starr, a retired businessman and an active investor, engaged in six series of futures straddles during 1978-80. Those straddles gave rise to short-term and long-term capital losses and gains, which were reported on petitioners' 1978, 1979, and 1980 tax returns. Respondent disallowed those gains and losses. Held: Petitioners have failed to meet their burden of proof in showing that petitioner Erwin Starr entered into the straddles at issue primarily for profit within the meaning of sec. 108(a) of the Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat. 494, 630-631, as…

1Opinion of the Court

ERWIN STARR AND HELEN STARR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Starr v. Commissioner

Docket No. 39314-84

United States Tax Court

T.C. Memo 1991-610; 1991 Tax Ct. Memo LEXIS 657; 62 T.C.M. (CCH) 1417; T.C.M. (RIA) 91610;

December 10, 1991, Filed

Petitioner Erwin Starr, a retired businessman and an active investor, engaged in six series of futures straddles during 1978-80. Those straddles gave rise to short-term and long-term capital losses and gains, which were reported on petitioners' 1978, 1979, and 1980 tax returns. Respondent disallowed those gains and losses. Held:…

2Cases cited12 opinions

  1. Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
  2. Glass v. CommissionerUnited States Tax Court · 1986
  3. Ewing v. CommissionerUnited States Tax Court · 1988
  4. Fox v. CommissionerUnited States Tax Court · 1984
  5. Smith v. CommissionerUnited States Tax Court · 1982

7 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Robert G. Leslie and Marilyn B. Leslie v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998

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