Hoover Company v. Commissioner: A Judicial One Way Street

Recently, the tax court in Hoover Company v. Commissioner,\u27 re- fused to apply the Corn Products doctrine3 and found that a corpora- tion\u27s forward sales agreements in foreign currencies were not hedging agreements.4 The court concluded that such sales did not constitute an integral part of the business,5 and thus losses from such transactions fell outside the protection of Corn Products and were afforded capital treat- ment.6 This note will suggest that the Hoover court, in focusing its deci- sion on the form of the taxpayer\u27s transaction (i.e., whether it was a bona fide hedge), failed to properly apply the integral part of busi- ness doctrine