108 T.C. No. 13
UNITED STATES TAX COURT
ESTATE OF LEON ISRAEL, JR., DECEASED,
BARRY W. GRAY, EXECUTOR, AND AUDREY H. ISRAEL, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
JONATHAN P. WOLFF AND MARGARET A. WOLFF, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 31588-88, 13142-89. Filed April 1, 1997.
Held: Fees paid in connection with "cancellation"
of legs of commodity forward contracts treated as
capital losses, not ordinary losses. The opinion of
the U.S. Court of Appeals for the District of Columbia
Circuit in Stoller v. Commissioner, 994 F.2d 855 (D.C.
Cir. 1993) (in its treatment of losses from
cancellation and replacement, and cancellation and
termination, of legs of commodity forward contracts as
ordinary losses) not followed, and our opinion in
Stoller v. Commissioner, T.C. Memo. 1990-659, affd. in
part and revd. in part 994 F.2d 855 (D.C. Cir. 1993)
(in its treatment of losses from cancellation and
termination of legs of commodity forward contracts as
ordinary losses), modified.
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