- 2 - 204(a)(7) of the Tax Reform Act of 1986 (TRA), Pub. L. 99-514, 100 Stat. 2146. We hold it is not. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the subject years. Rule references are to the Tax Court Rules of Practice and Procedure. Background All facts were stipulated and are so found. The stipulations of facts and the exhibits submitted therewith are incorporated herein by this reference. Petitioner is a corporation organized under the Illinois General Not for Profit Corporation Act to operate a commodity exchange in Chicago, Illinois. Its principal place of business is in Chicago, and it did not own any stock in a corporation during the relevant years. Petitioner primarily provides and regulates a commodity exchange where futures contracts and options on futures contracts are traded. Petitioner also establishes and enforces trading rules, collects and disseminates information about its markets, and provides the clearing mechanism for trades executed on its commodity exchange. Petitioner has no shareholders but is owned by its approximately 2,700 members, approximately 1/4 of which are corporations and the remainder of whom are individuals. Its member’s customers who have futures contracts and options traded on its commodity exchange are located worldwide, and it receives a significant portion of its income from foreign subscribers.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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