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A Case For Congressional Facilitation Of A Collaborative Model Of Statutory Interpretation In The Tax Area: Lessons To Be Learned From The Corn Products And Arkansas Best Cases And The Historical Development Of The Statutory Definition Of "Capital Asset(S)", Myron C. Grauer
Kentucky Law Journal
No abstract provided.
Taxation - Federal Income Tax - Treatment Of Gains From Commodity Futures Transactions Of Manufacturing Consumer, Neil Flanagin S.Ed.
Taxation - Federal Income Tax - Treatment Of Gains From Commodity Futures Transactions Of Manufacturing Consumer, Neil Flanagin S.Ed.
Michigan Law Review
Taxpayer, a manufacturer of products made from corn, purchased and sold corn futures contracts as a part of its regular buying program in order to protect itself against a possible shortage of raw materials. Taxpayer contended that the gains realized on these transactions should receive capital asset treatment. The Tax Court and the court of appeals held that the gains constituted ordinary income. On appeal, held, affirmed. The transactions, though not true hedges, were entered into for business purposes and as an integral part of taxpayer's operations. Consequently, they should be treated the same as hedges, and the gains …