Forseth v. Commissioner
United States Tax Court
P's were introduced to a company in London, LMEI, by an American corporation known as InterAct Trading Corp., to which they made certain payments. In late 1980, and in one instance, in late 1981, P's opened accounts with LMEI or its successor, LMEC, transmitting margin deposits and authorizing the companies to conduct discretionary trading in forward contracts in gold and platinum for such accounts.
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P's were introduced to a company in London, LMEI, by an American corporation known as InterAct Trading Corp., to which they made certain payments. In late 1980, and in one instance, in late 1981, P's opened accounts with LMEI or its successor, LMEC, transmitting margin deposits and authorizing the companies to conduct discretionary trading in forward contracts in gold and platinum for such accounts. In 1980 and 1981, P's claimed either ordinary or capital losses relative to straddle transactions reflected in their accounts. In 1980, certain P's also claimed advisory fee deductions for their…
1Opinion of the Court
Kórner, Judge:
Respondent determined deficiencies in Federal income taxes plus additions to tax against petitioners in these cases as follows:
Petitioners Additions to tax Docket No. Taxable year Deficiency sec. 6653(a)2
Arnold T. Forseth3 27126-82 12/31/80 $18,664.00 $933.00
Gerald R. Formsma and Constance Y. Formsma 1685-83 12/31/80 40,335.00 2,016.75
Stephen A. Mahoney III and Mary Ann Mahoney 7702-83 12/31/80 21,267.00
Richard H. Bramblett and Patsy J. Bramblett 7703-83 12/31/80 60,708.85 3,035.44
David C. Enrici and Marianne Enrici 32763-83 12/31/80 452,509.00
Raymond Wooldridge and Ida…
2Cases cited8 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Enoch v. CommissionerUnited States Tax Court · 1972
- Ernest J. Saviano and Margaret Saviano v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985
- Saviano v. CommissionerUnited States Tax Court · 1983
3 more not listed; retrieve them via the Exa API.
3Cited by80 opinions
- Freytag v. CommissionerUnited States Tax Court · 1987
- Glass v. CommissionerUnited States Tax Court · 1986
- Kenneth P. Kirchman and Budagail S. Kirchman, Leo P. Ayotte and Nancy C. Ayotte v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1989
- Ewing v. CommissionerUnited States Tax Court · 1988
- Brown v. CommissionerUnited States Tax Court · 1985
75 more not listed; retrieve them via the Exa API.