In a recent Tax Court decision the IRS won the case but may have lost the war. The case departed from prior decisions by recognizing a possible dual purpose in a business investment. Yet by finding that any substantial investment motive will preclude ordinary loss treatment under the Corn Products doctrine, the court may have created a boon to taxpayers in similar gain situations
Ronald B. Ravikoff,
Investment Motive Precludes Ordinary Loss Treatment,
30 U. Miami L. Rev.
Available at: http://repository.law.miami.edu/umlr/vol30/iss3/9