Estate of Israel v. Commissioner
United States Tax Court
Held: Fees paid in connection with "cancellation" of legs of commodity forward contracts treated as capital losses, not ordinary losses. The opinion of the U.S. Court of Appeals for the District of Columbia Circuit in Stoller v. Commissioner, 994 F.2d 855 (D.C.
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Held: Fees paid in connection with "cancellation" of legs of commodity forward contracts treated as capital losses, not ordinary losses. The opinion of the U.S. Court of Appeals for the District of Columbia Circuit in Stoller v. Commissioner, 994 F.2d 855 (D.C. Cir. 1993) (in its treatment of losses from cancellation and replacement, and cancellation and termination, of legs of commodity forward contracts as ordinary losses) not followed, and our opinion in Stoller v. Commissioner, T.C. Memo. 1990-659, affd. in part and revd. in part 994 F.2d 855 (D.C. Cir. 1993) (in its treatment of losses…
1Opinion of the Court
OPINION
Swift, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes and increased interest as follows:
Estate of Leon Israel, Jr., Deceased, and Audrey H. Israel
Increased interest Year Deficiency sec. 6621(c)
1977 ■€©■ CO 00 CO <1
1979 H-1 £*• to
Estate of Leon Israel, Jr., Deceased, and Audrey H. Israel — Continued
Increased interest Year Deficiency sec. 6621(c)
1980 62,482 1
Jonathan P. and Margaret A. Wolff
Year Deficiency Increased interest sec. 6621(c)
1979 $55,114 1
1980 82,369 1
1981 2,294 1
Unless otherwise indicated, all section references are to the Internal Revenue Code…
2Cases cited20 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
- Ewing v. CommissionerUnited States Tax Court · 1988
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3Cited by10 opinions
- Jonathan P. Wolff and Margaret A. Wolff v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
- General Signal Corporation, and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
- Buckrey v. Comm'rUnited States Tax Court · 2017
- Estate of Israel v. CommissionerCourt of Appeals for the D.C. Circuit · 1998
- CRI-Leslie, LLC v. Comm'rUnited States Tax Court · 2016
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