Missouri Pacific Railroad v. Southern Pacific Co.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding the taxpayer was an investor when he executed over 2,000 trades in 1979 and 1980 but held most stocks for over 1 year
• taxpayer who engaged in more than 1000 stock transactions over a year was not a securities “trader” under the Code
• taxpayer was an investor, despite extremely high volume of transactions, where \most of his sales were of securities held for over a year\ and he did not sell any security held less than 3 months
• stating the taxable-year requirement and collecting decisions from sister circuits
• deficiency notice referenced wrong year but attachments referenced correct year
• “The taxpayer must demonstrate that the notice was misleading.”

Source: CourtListener parenthetical corpus (CC0).