Legal Opinion

Hoover Co. v. Commissioner

United States Tax Court

Decided April 24, 1979No. Docket Nos. 2697-77, 9646-77PublishedCited by 34 opinions

Petitioner entered into 18 forward sale agreements to offset (1) a potential decline in the value of its investment in certain foreign subsidiaries, whose home currencies may be or are devalued relative to the U.S. dollar, and (2) exchange losses required to be reported on petitioner's consolidated financial statement.

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Petitioner entered into 18 forward sale agreements to offset (1) a potential decline in the value of its investment in certain foreign subsidiaries, whose home currencies may be or are devalued relative to the U.S. dollar, and (2) exchange losses required to be reported on petitioner's consolidated financial statement. Petitioner suffered losses on the closing of 16 of the sale agreements and realized gains on the sale of one contract and satisfaction of the remaining contract. Held: 1. The forward sale agreements do not constitute bona fide hedging transactions in commodity futures and the…

1Opinion of the Court

Dawson, Judge:

In these consolidated cases respondent determined the following deficiencies in petitioner’s Federal income taxes:

Deficiency TYE Dec. 31—

$192,775.71 1968

101,508.22 1969

60,005.53 1970

The primary issue presented for our decision is whether gains and losses from short sales in foreign currency engaged in by petitioner to offset (1) a potential decline in the value of its investment in certain foreign subsidiaries, whose home currencies may be or are devalued relative to the U.S. dollar, and (2) exchange losses required to be reported on petitioner’s consolidated financial…

2Cases cited58 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  3. United States v. Security Trust & Savings BankSupreme Court of the United States · 1950
  4. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  5. Board of Trade of Chicago v. Christie Grain & Stock Co.Supreme Court of the United States · 1905

53 more not listed; retrieve them via the Exa API.

3Cited by34 opinions

  1. Estate of Durkin v. CommissionerUnited States Tax Court · 1992
  2. National-Standard Co. v. CommissionerUnited States Tax Court · 1983
  3. Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
  4. Vickers v. CommissionerUnited States Tax Court · 1983
  5. Glacier State Electric Supply Co. v. CommissionerUnited States Tax Court · 1983

29 more not listed; retrieve them via the Exa API.

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