Grote v. Commissioner
United States Board of Tax Appeals
The purchases and sales of wheat futures by a wheat farmer, made entirely for protection against price fluctuations, held, related to his business of production and sale of wheat, and losses sustained in such transactions, held, not capital losses subject to the deduction limitations of section 117, Revenue Act of 1934.
1Opinion of the Court
*248OPINION.
SteRnhagen :
The taxpayers were wheat farmers and as shown by the evidence they bought and sold wheat futures on the Chicago Board of Trade entirely for the purpose of protection against pricei fluctuation. They were not speculators in the grain market as was the taxpayer in Staerker v. United States (U. S. Dist. Ct., N. Dist. of Texas, Sept. 23, 1938), or on the stock exchange as in O. L. Burnett, 40 B. T. A. 605. All of their transactions were related to their business of production and sale. They had books of account which included inventories and apparently the only reason that…
2Cited by8 opinions
- Hoover Co. v. CommissionerUnited States Tax Court · 1979
- Mansfield Journal Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1960
- Commissioner of Internal Rev. v. Farmers & G C. Oil Co.Court of Appeals for the Fifth Circuit · 1941
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Commissioner of Internal Revenue v. BanfieldCourt of Appeals for the Ninth Circuit · 1941
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