Legal Opinion

McCullough v. Commissioner

United States Tax Court

Decided December 31, 1990No. Docket Nos. 23294-87, 23340-87, 23585-87, 23592-87UnpublishedCited by 1 opinion

Between 1979 and 1986 petitioners invested funds in (1) a double trust scheme promoted by Frank Forrester, and (2) Mexican pagares (notes) purchased through a Mexican investment counsellor, Laura Antillon.

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Between 1979 and 1986 petitioners invested funds in (1) a double trust scheme promoted by Frank Forrester, and (2) Mexican pagares (notes) purchased through a Mexican investment counsellor, Laura Antillon. Petitioners did not recover all the funds they invested and on amended returns for the years 1982 through 1987, filed on Jan. 25, 1989, after these cases were scheduled for trial, they claimed deductions for theft losses arising out of those transactions for the year 1985, which produced net operating losses for 1985 which they carried back to the years 1982 through 1984. Respondent denied…

1Opinion of the Court

EDNA MCCULLOUGH, ET AL., 1 Petitioners v COMMISSIONER OF INTERNAL REVENUE, Respondent

McCullough v. Commissioner

Docket Nos. 23294-87, 23340-87, 23585-87, 23592-87

United States Tax Court

T.C. Memo 1990-653; 1990 Tax Ct. Memo LEXIS 728; 60 T.C.M. (CCH) 1514; T.C.M. (RIA) 90653;

December 31, 1990, Filed

Decisions will be entered under Rule 155.

Between 1979 and 1986 petitioners invested funds in (1) a double trust scheme promoted by Frank Forrester, and (2) Mexican pagares (notes) purchased through a Mexican investment counsellor, Laura Antillon. Petitioners did not recover all the funds they…

2Cases cited21 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Neely v. CommissionerUnited States Tax Court · 1985
  3. Grosshandler v. CommissionerUnited States Tax Court · 1980
  4. Boehm v. CommissionerSupreme Court of the United States · 1945
  5. Pallottini v. CommissionerUnited States Tax Court · 1988

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

3Cited by1 opinion

  1. William H. Geisler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1992

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