Hemmings v. Commissioner
United States Tax Court
Ps filed a refund suit in District Court for an overpayment of their 1984 tax, asserting that they were entitled to deductions which had not been claimed on their original income tax return and which related to commodity trading performed through C, a brokerage firm. The court entered summary judgment against Ps.
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Ps filed a refund suit in District Court for an overpayment of their 1984 tax, asserting that they were entitled to deductions which had not been claimed on their original income tax return and which related to commodity trading performed through C, a brokerage firm. The court entered summary judgment against Ps. R subsequently issued a notice of deficiency for the taxable years 1983 and 1984, determining that Ps were not entitled to deductions which had been claimed on their original income tax returns relating to trading activity with C. Ps moved for partial summary judgment, contending…
1Opinion of the Court
Isaac C. Hemmings and Mary Sue Hemmings, Petitioners v. Commissioner of Internal Revenue, Respondent
Hemmings v. Commissioner
Docket No. 9710-90
United States Tax Court
104 T.C. 221; 1995 U.S. Tax Ct. LEXIS 10; 104 T.C. No. 9;
February 6, 1995, Filed
An order will be issued denying petitioners' motion for partial summary judgment.
Ps filed a refund suit in District Court for an overpayment of their 1984 tax, asserting that they were entitled to deductions which had not been claimed on their original income tax return and which related to commodity trading performed through C, a brokerage firm. The…
2Cases cited45 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Migra v. Warren City School District Board of EducationSupreme Court of the United States · 1984
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
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