- 2 -
George B. Javaras, Barbara M. Angus, Richard E. Peterson,
and Raymond P. Wexler for petitioner.
Joseph T. Ferrick, for respondent.
BEGHE, Judge: Respondent determined deficiencies in
petitioner's Federal income tax for the years 1988, 1989, and
1990 in the amounts of $108,859, $113,473, and $65,051,
respectively.
The deficiencies arise from respondent’s inclusion in
petitioner’s gross income of membership transfer fees. The sole
issue is whether the membership transfer fees paid to petitioner
during 1988, 1989, and 1990 are contributions to capital or
payments for services. We hold the transfer fees to be excluded
from gross income as contributions to capital.
FINDINGS OF FACT
The parties have stipulated some facts, and the stipulation
of facts and the attached exhibits are incorporated in this
opinion. At all relevant times, petitioner maintained its
principal place of business in Chicago, Illinois.
Petitioner, the Board of Trade of the City of Chicago
(commonly referred to as the CBOT), is a taxable membership
corporation organized in 1859 under a special act of the Illinois
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011