United States Seventh Circuit

Where taxpayer was purely a speculator in U.S. Treasury securities, he was not entitled to offset trading losses against ordinary income as a "dealer" under 26 USC 1221(1).

Appellate Information

• Decided 11/08/2000
• Published 11/08/2000

Judges

• POSNER, Circuit Judge., Before POSNER, COFFEY, and KANNE, Circuit Judges.

Court

• United States Seventh Circuit

Counsel

• For Appellant:
  
• David J. Duez (argued), McDermott, Will & Emery, Chicago, IL, for Petitioners-Appellants.


• For Appellees:
  
• Gilbert S. Rothenberg, Edward T. Perelmuter (argued), Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for Respondent-Appellee.