Freytag v. Commissioner
United States Tax Court
Held, losses from transactions in forward contracts written by First Western Government Securities are not deductible.
1Opinion of the Court
OPINION
STERRETT, Chief Judge:
This case was assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) and Rule 180 et seq.1 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge:
There are currently more than 3,000 cases in this Court that involve the issues presented in these cases. The common denominator of all the cases is that each…
2Cases cited18 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Zmuda v. CommissionerUnited States Tax Court · 1982
- Marcello v. CommissionerUnited States Tax Court · 1964
- Glass v. CommissionerUnited States Tax Court · 1986
13 more not listed; retrieve them via the Exa API.
3Cited by288 opinions
- Freytag v. CommissionerSupreme Court of the United States · 1991
- Ernest P. Kline v. First Western Government Securities, Inc.Court of Appeals for the First Circuit · 1994
- Louis Buddy Yosha v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Glenn A. Mortensen v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- Harold Chakales Linda Carol Chakales v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1996
283 more not listed; retrieve them via the Exa API.