United States Tax Court December 23, 2009, Docket 1283-07 (BLAK Investments, Kyle W. Manroe Trust, Robert and Lori Manroe, Trustees, Tax Matters Partner v. Commissioner)

combined-opinion

133 T.C. No. 19

UNITED STATES TAX COURT

BLAK INVESTMENTS, KYLE W. MANROE TRUST, ROBERT AND LORI MANROE,

TRUSTEES, TAX MATTERS PARTNER, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 1283-07. Filed December 23, 2009.

In 2001 two partners of partnership P borrowed

Treasury securities and sold them in the open market;

i.e., a short sale.