Jeff Hochberg Quoted in Tax Notes Today on Interpretation of Section 1234A

February 27, 2015

On February 27, Tax Notes Today quoted Mr. Hochberg in the article “Practitioners Welcome Pro-Taxpayer Pilgrim's Pride.” The article covered the Fifth Circuit Court of Appeals' recent opinion on Pilgrim's Pride, which said a taxpayer may realize ordinary losses in a pre-2008 abandonment of stock. “The Tax Court's prior interpretation of section 1234A under which stock could be treated as a 'right or obligation… with respect to property which is a capital asset in the hands of the taxpayer' for section 1234A purposes relied on a strained reading of section 1234A,” said Mr. Hochberg.