Legal Opinion

Rosenthal v. Commissioner

United States Tax Court

Decided November 30, 1970No. Docket Nos. 67848, 77923-77925, 93832, 1986-62, 1392-64, 1393-64Unpublished

Issue 1: Government Bonds Transactions. (a) Held, upon the facts: That in each one of the four transactions involving $1,000,000 Federal Land Bank bonds, $100,000 U.S.

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Issue 1: Government Bonds Transactions. (a) Held, upon the facts: That in each one of the four transactions involving $1,000,000 Federal Land Bank bonds, $100,000 U.S. Treasury bonds, $100,000 Treasury bonds, and $750,000 Treasury notes, respectively, the petitioner, Jerome B. Rosenthal, did not enter into a bona fide transaction in each instance on February 17, 1953, February 26, 1954, March 1, 1954, and December 23, 1955, respectively, for the purchase of the securities which purportedly were involved; that each transaction was without substance and reality and was a sham transaction; that…

1Opinion of the Court

Jerome B. Rosenthal and Ruth Rosenthal 1 v. Commissioner.

Rosenthal v. Commissioner

Docket Nos. 67848, 77923-77925, 93832, 1986-62, 1392-64, 1393-64.

United States Tax Court

T.C. Memo 1970-332; 1970 Tax Ct. Memo LEXIS 28; 29 T.C.M. (CCH) 1521; T.C.M. (RIA) 70332;

November 30, 1970, Filed.

Issue 1: Government Bonds Transactions. (a) Held, upon the facts: That in each one of the four transactions involving $1,000,000 Federal Land Bank bonds, $100,000 U.S. Treasury bonds, $100,000 Treasury bonds, and $750,000 Treasury notes, respectively, the petitioner, Jerome B. Rosenthal, did not enter into a bona…

2Cases cited88 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Helvering v. TaylorSupreme Court of the United States · 1935
  4. Knetsch v. United StatesSupreme Court of the United States · 1960
  5. Helvering v. National Grocery Co.Supreme Court of the United States · 1938

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