Burrill v. Commissioner
United States Tax Court
Petitioner allegedly incurred short-term capital losses when he engaged a foreign investment bank to trade at its discretion metals futures on his behalf. The only documentary evidence of the trades and losses consists of confirmation notices from the foreign bank to petitioner.
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Petitioner allegedly incurred short-term capital losses when he engaged a foreign investment bank to trade at its discretion metals futures on his behalf. The only documentary evidence of the trades and losses consists of confirmation notices from the foreign bank to petitioner. Petitioner allegedly borrowed $ 1 million from the bank on Dec. 16, 1980; within 8 days he apparently lost $ 1,000,750, which he deducted for 1980. Petitioner allegedly borrowed $ 300,000 from an entity related to the bank on Oct. 15, 1981; by Dec. 28, 1981, he apparently lost $ 358,800, which he deducted for 1981.…
1Opinion of the Court
Gary Burrill, Petitioner v. Commissioner of Internal Revenue, Respondent
Burrill v. Commissioner
Docket No. 40204-84
United States Tax Court
93 T.C. 643; 1989 U.S. Tax Ct. LEXIS 150; 93 T.C. No. 54;
December 11, 1989; As corrected December 21, 1989 December 11, 1989, Filed
Decision will be entered under Rule 155.
Petitioner allegedly incurred short-term capital losses when he engaged a foreign investment bank to trade at its discretion metals futures on his behalf. The only documentary evidence of the trades and losses consists of confirmation notices from the foreign bank to petitioner. Petitioner…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Beard v. Comm'rUnited States Tax Court · 1984
- Robert D. Beard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
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