Cook v. Commissioner
United States Tax Court
Held, availability to petitioner of per se dealer rule determined under sec. 108(b) of the Tax Reform Act of 1984 (Division A of the Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat. 494, 630), as amended by sec. 1808(d) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, 2817.
1Opinion of the Court
OPINION
NlMS, Judge:
This matter is before the Court on petitioner’s motion for reconsideration of findings and opinion. Petitioner was one of the petitioners in the London options consolidated group as to which the Court published an opinion denominated Glass v. Commissioner, 87 T.C. 1087 (1986) (Court-reviewed).
On November 23, 1987, the Court promulgated the following:
ORDER
On June 17, 1987, petitioner in the case at docket No. 3122-82 filed a Motion for Reconsideration of Findings and Opinion in Glass v. Commissioner, 87 T.C. 1087 (1986). Petitioner’s Motion for Reconsideration of Findings…
2Cases cited11 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Train v. Colorado Public Interest Research Group, Inc.Supreme Court of the United States · 1976
- Glass v. CommissionerUnited States Tax Court · 1986
- James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
6 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Laureys v. CommissionerUnited States Tax Court · 1989
- Katz v. CommissionerUnited States Tax Court · 1988
- Terence J. Horn and Jean Horn v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Terence J. Horn and Jean HornCourt of Appeals for the D.C. Circuit · 1992
- Lerman v. CommissionerCourt of Appeals for the Third Circuit · 1991
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