Jeffrey A. Galant of Meltzer, Lippe, Goldstein & BreitstoneKISS, Profit Motive and Foreign Currency Contracts
The author writes "While being careful to dot their “i’s” and cross their “t’s” with respect to the complicated rules of section 1256 of the Internal Revenue Code, this attention to detail only took the Wrights so far in their quest to offset substantial capital gains that they had realized in 2002. They apparently gave little thought to section 165(c)’s limitation on an individual’s ability to deduct losses. More about this shortly."
December 24, 2024 at 11:00 AM
10 minute read
By Jeffrey A. Galant
Great artists, including the likes of Rodin, Munch, Klimt and Schiele, have portrayed in various ways the simple and very human act of kissing. Behind the scenes, of course, one can imagine the complex nature of things.
Admittedly, it is an imperfect metaphor for promoting an adherence to the KISS principle (i.e., keeping it simple), especially when engaging in tax sensitive transactions such as trading foreign currency contracts. The case of the Wrights suggests its relevance. (Wright v. Commissioner, TC Memo 2024-100)
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