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INTERNATIONAL FLAVORS & FRAGRANCES, INC. v. COMMISSIONER

Docket No. 7768-70.

36 T.C.M. 260 (1977)

T.C. Memo. 1977-58

International Flavors & Fragrances, Inc. v. Commissioner.

United States Tax Court.

Filed March 9, 1977.

Attorney(s) appearing for the Case

George Rowe, Jr., 30 Rockefeller Plaza, New York, N.Y. and Michael J. Gaynor, for the petitioner. Theodore J. Kletnick, for the respondent.

Supplemental Memorandum Opinion

QUEALY, Judge:

In our opinion filed May 16, 1974 ([Dec. 32,599] 62 T.C. 232), this Court held that a contract entered into by International Flavors & Fragrances, Inc., (hereinafter referred to as "petitioner") for the future delivery of 1.1 million British pounds sterling at $2.7691 per pound (at short sale) did not constitute a capital asset in...

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