Corn Prods. Ref. Co. v. Comm'r of Internal Revenue

1 Citing case

  1. Hoover Co. v. Comm'r of Internal Revenue

    72 T.C. 206 (U.S.T.C. 1979)   Cited 13 times
    In Hoover the tax court, on facts indistinguishable for the present purposes from those of the instant case, held, as the taxpayer urges here, that a loss from a currency exchange transaction intended to offset a currency devaluation paper loss in the value of a foreign subsidiary had to receive the same tax treatment as would a gain or loss on the parent company's interest in the subsidiary.

    This amendment, Congress believed, would prevent any unintended application of any of the subsections of section 1233 to bona fide hedging transactions. In 1955, the limited concept of hedging, with its strict requirements of balanced market position and relationship of the commodity future to the business operations of the taxpayer, was blurred by the decision in Corn Products Refining Co. v. Commissioner, 350 U.S. 46 (1955), affg. 215 F.2d 513 (2d Cir. 1954), affg. 16 T.C. 395 (1951), as supplemented 20 T.C. 503 (1953). In Corn Products, the taxpayer was engaged in the production of distilled products from corn.