Bielfeldt v. Commissioner
United States Court of Appeals for the Seventh Circuit
231 F.3d 1035 (2000)
Gary Bielfeldt (plaintiff) speculatively purchased and sold U.S. Treasury securities. When Bielfeldt identified an opportunity to make a short-term profit on Treasury securities, he entered into buy-and-sell transactions with primary dealers. Bielfeldt participated in Treasury auctions only a few weeks each year at most. Bielfeldt would also go for months without owning any Treasury securities at all. After sustaining heavy losses on the securities transactions, Bielfeldt sought a refund of $85 million on his federal income taxes, which exceeded the annual capital-loss deduction limit. The United States Tax Court entered judgment in favor of the United States government (defendant). Bielfeldt appealed to the United States Court of Appeals for the Seventh Circuit.
Rule of Law
Holding and Reasoning (Posner, J.)
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