# Hoover Co. v. Commissioner

> United States Tax Court · April 24, 1979 · 72 T.C. 206

URL: https://www.frixlaw.com/law-library/cases/4483973

## Case

- **Full name:** The Hoover Company v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** April 24, 1979
- **Citations:** 72 T.C. 206; 1979 U.S. Tax Ct. LEXIS 132
- **Precedential status:** Published
- **Opinion:** Concurrence by Tannenwald
- **Judges:** Dawson,Tannenwald,Drennen,Chabot
- **Cited by:** 22 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4483973

## Opinion text

Tannenwald, J., concurring: The parties herein presented their positions in a narrow frame of reference and the disposition by the Court of Appeals of International Flavors & Fragrances, Inc. v. Commissioner, 524 F.2d 357 (2d Cir. 1975), revg. and remanding 62 T.C. 232 (1974), injected a further complication, particularly in light of the Government’s abandonment on appeal of any reliance on Corn Products Refining Co. v. Commissioner, 350 U.S. 46 (1955). I am, therefore, in agreement with the majority decision and the rationale upon which it rests, insofar as this case is concerned.
However, I do not consider the majority opinion as precluding the application of Corn Products Refining Co. v. Commissioner, supra, or a variant of the principles articulated therein, in all situations involving foreign currency transactions by corporations having foreign operations. In the complex present-day world economy and the equally complex methods of doing business by multinational corporations, whether through subsidiaries or branches, there may be situations in which ordinary gain and/or loss treatment of such transactions would be justified.
Drennen, J., agrees with this concurring opinion.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4483973. Public record. Not legal advice.