Willard Helburn, Inc. v. Commissioner
United States Tax Court
Realization of Income -- Foreign Funds. -- The petitioner borrowed pounds sterling in England in an amount sufficient to pay for lambskins to be used in its business, the cost of which in dollars at the $ 4.04 exchange rate then in effect would have been $ 276,108.20. Later, when the exchange rate had gone down to $ 2.81, it repaid the loans by using only $ 192,060.84. The difference of $ 84,047.36 was taxable income from dealing in foreign exchange.
1Opinion of the Court
OPINION".
Murdock, Judge:
The Commissioner determined a deficiency of $42,461.82 in income tax of the petitioner for its fiscal year ended November 30, 1949. The only issue for decision is whether the petitioner realized taxable income of $84,047.36, the difference between the dollar value of pounds sterling borrowed to purchase skins and dollars expended to purchase pounds sterling to repay the loan. The facts have been presented by a stipulation which is adopted as the findings of fact.
The petitioner filed its corporate income tax return for its fiscal year ended November 30, 1949, with the…
2Cases cited1 opinion
- B. F. Goodrich Co. v. CommissionerUnited States Tax Court · 1943
3Cited by28 opinions
- Durovic v. CommissionerUnited States Tax Court · 1970
- Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Levin v. CommissionerUnited States Tax Court · 1986
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
- National-Standard Co. v. CommissionerUnited States Tax Court · 1983
23 more not listed; retrieve them via the Exa API.