Henry E. & Nancy Horton Bartels Trust for the Benefit of the University of New Haven v. United States

WEXLER, District Judge:

Plaintiff-appellant The Henry E. & Nancy Horton Bartels Trust for the Benefit of the University of New Haven (“Taxpayer”), appeals from a judgment of the United States District Court for the District of Connecticut (Eginton, J.), upon an order granting Taxpayer’s motion for reconsideration and, on reconsideration, affirming an order granting the government’s motion for summary judgment and denying Taxpayer’s cross-motion for summary judgment in Taxpayer’s refund action. Because we agree with the district court that Taxpayer’s securities purchased on margin constitute…