BIELFELDT V. COMMISSIONER
231 F.3d 1035 (7th Cir. 2000)
NATURE OF THE CASE: Gary Bielfeldt (P), a large trader in U.S. Treasury notes and bonds,
seeks to overturn a decision by the Tax Court denying him the right to offset immense
trading losses that he incurred in the1980s against all but $3,000 a year in ordinary income.
FACTS: P claims to be a dealer and that the losses he incurred in the sale of the
Treasury securities were losses connected with his dealer's 'stock in trade.' If this were
so, P claims that such losses, even when they result as his did from the sale of a capital
asset, are treated as ordinary rather than capital losses and can therefore be fully offset
against ordinary income. 26 U.S.C. sec. 1221(1). P appealed from adverse determinations.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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