Corn Products Refining Company v. Commissioner, 350 U.S. 46 (1955), is a United States Supreme Court decision that helps taxpayers classify whether or not the disposition of a commodity futures contract by a business of raw materials as part of its hedging of business risk is an ordinary or capital gain or loss for income tax purposes.
Even though the petitioner's actions were not true hedging (which would include protections against a fall in price), the purchase of the futures were an integral part of its manufacturing business.
The Court reasoned that the broad definition of the term "capital asset" does not bring operations of a business.
Hedging transactions that are an integral part of a business's inventory-purchase system fall within the inventory exclusion of section 1221.
This is essentially a codification of the result in Corn Products and removes the necessity of classifying hedging transactions as "inventory" under IRC § 1221(a)(1).