King v. Commissioner
United States Tax Court
Petitioner was engaged in the trade or business of commodities futures trading. In 1978, petitioner took delivery of 10,000 ounces of gold pursuant to the terms of 100 long gold futures contracts. In 1980, petitioner disposed of the gold pursuant to 100 short gold futures contracts. Petitioner realized a long-term capital gain with respect to his disposition of the gold.
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Petitioner was engaged in the trade or business of commodities futures trading. In 1978, petitioner took delivery of 10,000 ounces of gold pursuant to the terms of 100 long gold futures contracts. In 1980, petitioner disposed of the gold pursuant to 100 short gold futures contracts. Petitioner realized a long-term capital gain with respect to his disposition of the gold. During the years 1979 and 1980, petitioner deducted interest expenses resulting from carrying the physical gold. Held, to the extent a trader has incurred debt in order to carry on ordinary trading activities as part of his…
1Opinion of the Court
CLAPP, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
Year Deficiency
1979 . $19,989.34
1980 . 1,525,852.76
Following the granting of petitioner’s motion for partial summary judgment in King v. Commissioner, 87 T.C. 1213 (1986), the only issue remaining for our decision is whether section 163(d) 1 is applicable to certain interest deductions claimed by petitioner for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation and attached exhibits are incorporated herein by this reference. Petitioner…
2Cases cited15 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Higgins v. CommissionerSupreme Court of the United States · 1941
- W. W. Windle Co. v. CommissionerUnited States Tax Court · 1976
- Wood v. CommissionerUnited States Tax Court · 1951
- Commissioner of Internal Revenue v. CovingtonCourt of Appeals for the Fifth Circuit · 1941
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3Cited by51 opinions
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- Guardian Indus. Corp. v. CommissionerUnited States Tax Court · 1991
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