Barrett v. Commissioner
United States Tax Court
In 1981, P bought and sold options to buy stock, realizing a large profit which was reported for 1981 as short-term capital gain. The Securities and Exchange Commission (SEC) charged that P had used insider information in buying the options, and instituted proceedings to cancel his license as a broker. Certain other brokers filed lawsuits against P and others seeking $ 10 million. In 1984 the lawsuits were settled, with P paying $ 54,400 to the plaintiffs.
Read the full summary
In 1981, P bought and sold options to buy stock, realizing a large profit which was reported for 1981 as short-term capital gain. The Securities and Exchange Commission (SEC) charged that P had used insider information in buying the options, and instituted proceedings to cancel his license as a broker. Certain other brokers filed lawsuits against P and others seeking $ 10 million. In 1984 the lawsuits were settled, with P paying $ 54,400 to the plaintiffs. P also paid $ 17,721.79 in legal fees. The SEC dismissed its charges. Held, petitioners are entitled to a credit under sec. 1341(a)(5),…
1Opinion of the Court
Joseph A. Barrett and Pauline C. Barrett, Petitioners v. Commissioner of Internal Revenue, Respondent
Barrett v. Commissioner
Docket No. 3028-89
United States Tax Court
96 T.C. 713; 1991 U.S. Tax Ct. LEXIS 37; 96 T.C. No. 31;
May 20, 1991, Filed
Decision will be entered under Rule 155.
In 1981, P bought and sold options to buy stock, realizing a large profit which was reported for 1981 as short-term capital gain. The Securities and Exchange Commission (SEC) charged that P had used insider information in buying the options, and instituted proceedings to cancel his license as a broker. Certain other…
2Cases cited24 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Lyeth v. HoeySupreme Court of the United States · 1938
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Healy v. CommissionerSupreme Court of the United States · 1953
19 more not listed; retrieve them via the Exa API.