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SICANOFF VEG. OIL CORP. v. COMMISSIONER OF INT. REV.

Nos. 12095, 12096.

251 F.2d 764 (1958)

SICANOFF VEGETABLE OIL CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. SICANOFF TALLOW CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

January 29, 1958.

Attorney(s) appearing for the Case

John W. Hughes, Harold R. Burnstein, John E. Hughes, Chicago, Ill., for petitioners.

Charles K. Rice, Asst. Atty. Gen., I. Henry Kutz, Lee A. Jackson, James P. Turner, Attorneys, Department of Justice, Washington, D. C., for respondent.

Before DUFFY, Chief Judge, and FINNEGAN and HASTINGS, Circuit Judges.

HASTINGS, Circuit Judge.

Petitioners, Sicanoff Vegetable Oil Corporation and Sicanoff Tallow Corporation, appeal from a decision of the Tax Court of the United States which sustained the Commissioner of Internal Revenue's determination that 80% of their gross income for 1950 consisted of gains from futures transactions in commodities subject to the rules of a board of trade or commodity exchange, none of which gains resulted from bona fide hedging transactions reasonably...

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