Hoover Co. v. Commissioner
United States Tax Court
Petitioner entered into 18 forward sale agreements to offset (1) a potential decline in the value of its investment in certain foreign subsidiaries, whose home currencies may be or are devalued relative to the U.S. dollar, and (2) exchange losses required to be reported on petitioner's consolidated financial statement.
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Petitioner entered into 18 forward sale agreements to offset (1) a potential decline in the value of its investment in certain foreign subsidiaries, whose home currencies may be or are devalued relative to the U.S. dollar, and (2) exchange losses required to be reported on petitioner's consolidated financial statement. Petitioner suffered losses on the closing of 16 of the sale agreements and realized gains on the sale of one contract and satisfaction of the remaining contract. Held: 1. The forward sale agreements do not constitute bona fide hedging transactions in commodity futures and the…
1Opinion of the Court
The Hoover Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Hoover Co. v. Commissioner
Docket Nos. 2697-77, 9646-77
United States Tax Court
72 T.C. 206; 1979 U.S. Tax Ct. LEXIS 132;
April 24, 1979, Filed
Decisions will be entered under Rule 155.
Petitioner entered into 18 forward sale agreements to offset (1) a potential decline in the value of its investment in certain foreign subsidiaries, whose home currencies may be or are devalued relative to the U.S. dollar, and (2) exchange losses required to be reported on petitioner's consolidated financial statement. Petitioner suffered…
Also in this document: Concurrence; Dissent.
2Cases cited71 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Labor Relations Board v. Catholic BishopSupreme Court of the United States · 1979
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
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