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Income Tax Keyed to Bankman
Bielfeldt v. Commissioner
Citation:
231 F.3d 1035 (7th Cir. 2000)Facts
In the 1980s, Petitioner incurred immense trading losses from the sale of securities which he offset against his ordinary income. Petitioner claimed that he was essentially engaged in the function of a primary dealer by purchasing large amounts of Treasury securities that affected the securities market, though he was not working directly with the Treasury. The Commissioner of Internal Revenue determined that Petitioner was acting as a trader and not as a dealer and that he had incurred capital losses that could only be offset against Petitioner’s ordinary income in the amount of $3,000 as prescribed by Section 1211(b) of the Internal Revenue Code.
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