Corn Products Refining Company (Corn Products) (plaintiff), a manufacturer of corn products, bought and sold corn-futures commodity contracts in order to ensure that Corn Products had an adequate supply of corn at economical prices. On its corn-futures contracts, Corn Products netted a profit in 1940, followed by a loss in 1942. Corn Products asserted that its gains and losses in corn futures should have been treated as arising from the sale of capital assets. Corn Products claimed that its futures-buying program was an investment program separate from its manufacturing business. The federal tax commissioner (commissioner) (defendant) determined a deficiency in Corn Products’ taxes. Corn Products petitioned the United States Tax Court for a redetermination. The tax court entered judgment in favor of the commissioner, holding that the corn futures did not arise from the sale of capital assets. The court of appeals affirmed. The United States Supreme Court granted certiorari.