Bielfeldt v. Commissioner

231 F.3d 1035 (7th Cir. 2000)

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Nature of the Case

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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.