Legal Opinion
Commissioner of Internal Revenue v. Wilson
Court of Appeals for the Ninth Circuit
Decided September 15, 1947No. 11517PublishedCited by 11 opinions
1Opinion of the Court
GARRECHT, Circuit Judge.
The Commissioner of Internal Revenue petitions for review of the decision of the Tax Court in the above case. Petitioner contends that the Court erred in allowing as expenses dividends paid on stocks in which the respondent had a short position. The facts were presented by stipulation which were adopted as findings and are as follows:
Respondent throughout the taxable years 1938, 1939 and 1940 was engaged as a trader in the business of dealing in securities on his own account. He made many short sales of securities, and was continuously in a short position as a trader.…
2Cases cited12 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Helvering v. WinmillSupreme Court of the United States · 1938
- Wilmington Trust Co. v. HelveringSupreme Court of the United States · 1942
- Provost v. United StatesSupreme Court of the United States · 1926
- Spreckels v. CommissionerSupreme Court of the United States · 1942
7 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Main Line Distributors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1963
- Main Line Distributors, Inc. v. CommissionerUnited States Tax Court · 1962
- Cameron v. CommissionerUnited States Tax Court · 1983
- Wakelee v. CommissionerUnited States Tax Court · 1951
- 1955 Production Exposition, Inc. v. CommissionerUnited States Tax Court · 1963
6 more not listed; retrieve them via the Exa API.