Legal Opinion

Carborundum Co. v. Commissioner

United States Tax Court

Decided July 21, 1980No. Docket No. 2338-75PublishedCited by 16 opinions

Held, petitioner realized long-term capital gain on the sales of currency contracts in 1968.

1Opinion of the Court

Wiles, Judge:

Respondent determined a deficiency of $229,049 in petitioner’s 1968 Federal income tax. The sole issue for decision is whether petitioner realized short-term or long-term capital gain from the sale of foreign currency contracts.

FINDINGS OF FACT

This case has been fully stipulated and the facts are found accordingly.

The Carborundum Co. (hereinafter petitioner) is a corporation organized and existing under the laws of the State of Delaware with its principal offices located at Niagara Falls, N.Y. Petitioner filed a timely consolidated Federal income tax return for calendar year 1968…

2Cases cited15 opinions

  1. Universal Battery Co. v. United States and Four Other CasesSupreme Court of the United States · 1930
  2. Edwin W. Hudspeth and Maxine G. Hudspeth v. United StatesCourt of Appeals for the Eighth Circuit · 1972
  3. Commissioner of Internal Revenue v. Percy W. Phillips and Betty R. Phillips (Husband and Wife)Court of Appeals for the Fourth Circuit · 1960
  4. John P. Kinsey and Edith B. Kinsey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973
  5. Hobby v. CommissionerUnited States Tax Court · 1943

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

3Cited by16 opinions

  1. Rauenhorst v. Comm'rUnited States Tax Court · 2002
  2. Vickers v. CommissionerUnited States Tax Court · 1983
  3. Estate of Applestein v. CommissionerUnited States Tax Court · 1983
  4. Ferguson v. CommissionerUnited States Tax Court · 1997
  5. Peterson Irrevocable Trust 2 for benefit of Peterson v. CommissionerUnited States Tax Court · 1986

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

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