Staple Gin Co. v. United States

164 F. Supp. 919, 2 A.F.T.R.2d (RIA) 5363, 1958 U.S. Dist. LEXIS 3912
CourtDistrict Court, S.D. Texas
DecidedJune 26, 1958
DocketCiv. A. No. 1615
StatusPublished

This text of 164 F. Supp. 919 (Staple Gin Co. v. United States) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Staple Gin Co. v. United States, 164 F. Supp. 919, 2 A.F.T.R.2d (RIA) 5363, 1958 U.S. Dist. LEXIS 3912 (S.D. Tex. 1958).

Opinion

ALLRED, District Judge.

This is an action for the recovery of corporate income tax deficiency in the amount of $5,121, paid by plaintiff for the calendar year 1952, with interest amounting to $1,089.01. The question presented is whether $17,070 of losses sustained by plaintiff in 1952 in commodity futures transactions were ordinary and necessary expenses paid or incurred by plaintiff during that year in the carrying on of the trade or busi[920]*920ness of cotton ginning within the meaning of Section 23(a), 1939 Internal Revenue Code, 26 U.S.C.A. § 23(a). Stated in other words, and as set out in a pre-trial order, the issue is: whether or not the $17,070 ordinary loss deduction on plaintiff’s tax return for the calendar year 1952, resulting from losses sustained in commodity futures transactions entered into during that year, were “hedging” losses, deductible as ordinary business expense; or, as maintained by defendant, that said commodity futures transaction losses were “speculative” losses which would result in capital loss, therefore not deductible from plaintiff’s gross income for 1952.

Plaintiff operates a cotton gin in which its income is derived from (1) a service charge for ginning the cotton; (2) a small profit on bagging and ties; and (3) the main profit from the purchase and sale of. cottonseed. Purchases are from farmers ginning their cotton at plaintiff’s gin during the short season of July and August. Cottonseed oil mills are the real buyers for the cottonseed. They quote a price on cottonseed to the gins at regular intervals and advise them every time they change the price. The ginner changes his price up or down accordingly and works on a differential or margin of profit. Plaintiff acquires the seed, usually at so much per ton less than it is able immediately to get for it from the oil mill. Plaintiff does not store any appreciable quantities of seed, or any at all for any appreciable time. It makes a quick turnover profit on an average of not more than ten days between purchase and sale, sometimes having the cottonseed sold at the time of purchase. Plaintiff’s profit averages $9 per ton.

In February 1952 plaintiff entered into a contract on the Chicago Board of Trade for the short sale of 900 tons of soybean meal for July 1952 delivery. Plaintiff’s president and principal stockholder, McDaniel, testified that this was the result of a decision of the officers and management of the corporation1 to sell this soybean meal against cottonseed that was being grown by farmers in the area from whom the gin would buy it and immediately resell it to cotton oil mills; that there was no intent to speculate on the sale of these futures; that the management thought that the cottonseed market couldn’t go any way except down and they were protecting the gin’s interests; that crop conditions were ideal and they expected a bumper cotton crop which would cause the price of cottonseed to go down; that if this expectation had proved correct, it would have affected the ginner’s profits in this way: that the gin would sell the seed

and when they bought from the farmers, naturally if the prices were down the ginner would have a bigger margin in them.

McDaniel insisted that the purpose of the short sale of soybean meal futures was to “hedge” since the gin confidently expected a bumper crop and resulting low prices for cottonseed; that the reason it didn’t hedge with cottonseed meal was that it was handled only on the Memphis Board of Trade and it is not a very active market while soybean meal is handled on the Chicago Board of Trade, a very active market, and that prices were not quoted on cottonseed; that soybean meal competes in a market with cottonseed meal and, therefore, it is and can be used as a hedge against cottonseed; that if the price had declined on cottonseed in 1952, then he believed that he would have been able to shift the risk to something else; that “if the price had declined on one, we figured it would be the same on the other”; that he [921]*921was just 100% wrong and sustained the loss in question.2

Plaintiff’s counsel frankly concedes that this soybean transaction was “unique” and not a “typical” hedging operation, certainly as that term had been understood before Corn Products Refinery Co. v. Commissioner, 350 U.S. 46, 76 S.Ct. 20, 24, 100 L.Ed. 29; but he insists that under the holding in that case and the reasoning in others,3 the loss here was an ordinary and necessary expense paid or incurred in carrying on the gin’s business in the taxable year.

In the Corn Products case the Court held that purchases and sales of corn futures in order to assure the company an adequate supply to meed demands throughout the year, and designed to guard against price increases, were an integral part of the business, the profits and losses of which must be considered as ordinary, rather than capital, gain or loss; that while the hedge there was not a “true” one, yet a hedge could be against either a price increase or a price decline. The Court pointed to the Treasury Department’s ruling in G.C.M. 17322, “distinguishing speculative transactions in commodity futures from hedging transactions. It held that hedging transactions were essentially to be regarded as insurance rather than a dealing in capital assets and that gains and losses therefrom were ordinary business gains and losses.” 4 The court further pointed out that this treasury memorandum had been followed consistently by the courts as well as by the Commissioner, and acquiesced in by Congress.

There are many differences and distinctions between Corn Products and the facts here. Perhaps none of them alone would be controlling but, on the whole, they completely repudiate the idea that plaintiff’s short sale of soybean meal can be recognized as a hedging operation under the treasury memorandum or the cases. They compel the conclusion that this transaction was pure speculation despite the testimony of McDaniel that it was intended as a hedge. His own testimony shows, I think, that in his own mind it was not a “hedge.” He was hard put to state in understandable language, even in reply to leading questions, just what the gin was hedging against.

The gin had no cottonseed in storage or in inventory. It had none contracted for. It did not buy or expect to buy cottonseed for four to five months and then it would be for a quick turnover. It was not growing cotton. It expected to purchase cottonseed from farmers ginning with it at prices below what it knew the oil mills immediately would pay for it. Its profits from buying and selling cottonseed averaged $9 per ton. Its earnings, therefore, would vary, depending upon the size of the cotton crop in the area and the number of bales ginned. The better the crop, the more tons of cottonseed, theoretically, would be bought and sold; but the average profit per ton would remain the same. True a bumper crop would mean lower prices for cottonseed as McDaniel testified, but that would not affect plaintiff’s profits, except that a good crop, with consequent lower prices, would mean that plaintiff would buy and sell more cottonseed, in other words, do a greater volume of business. As a matter of fact plaintiff’s average net profit in the tax year was $9 per ton.

Generally, of course, a hedging operation is thought of in the same sense as the definition given by Mr. William L.

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Related

Kornhauser v. United States
276 U.S. 145 (Supreme Court, 1928)
Welch v. Helvering
290 U.S. 111 (Supreme Court, 1933)
Lilly v. Commissioner
343 U.S. 90 (Supreme Court, 1952)
Corn Products Refining Co. v. Commissioner
350 U.S. 46 (Supreme Court, 1956)
Patterson v. Hightower
245 F.2d 765 (Fifth Circuit, 1957)
Muth v. Aetna Oil Co.
342 U.S. 954 (Supreme Court, 1952)

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Bluebook (online)
164 F. Supp. 919, 2 A.F.T.R.2d (RIA) 5363, 1958 U.S. Dist. LEXIS 3912, Counsel Stack Legal Research, https://law.counselstack.com/opinion/staple-gin-co-v-united-states-txsd-1958.