Legal Opinion
Killingsworth v. Commissioner
Court of Appeals for the Fifth Circuit
Decided February 8, 1989No. Nos. 87-4623, 88-4227 and 88-4551PublishedCited by 49 opinions
1Opinion of the Court
JOHNSON, Circuit Judge:
Petitioners/appellants appeal from a decision of the Tax Court which disallowed their claimed tax deductions for losses incurred as a result of straddle transaction trading on the London Metal Exchange. For the reasons cited herein, we affirm.
I. FACTS AND PROCEDURAL HISTORY
At issue in this case is the deductibility of losses allegedly incurred by taxpayers as a result of trading on the London Metal *1216Exchange, or, as the Seventh Circuit appropriately characterized the controversy, the “eternal tension between form and substance.” 1 The transactions involved here are the…
2Cases cited18 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Glass v. CommissionerUnited States Tax Court · 1986
13 more not listed; retrieve them via the Exa API.
3Cited by49 opinions
- Halpern v. CommissionerUnited States Tax Court · 1991
- Preston W. And Joyce Massengill v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1989
- Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Lewis Arthur Merryman v. Commissioner of Internal Revenue, Michael A. Carroll and Margaret W. Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1989
- James v. CommissionerCourt of Appeals for the Tenth Circuit · 1990
44 more not listed; retrieve them via the Exa API.