The Commissioner determined a deficiency of $163,804.78 in the income tax of the petitioner and an affiliate for 1940. The issues in dispute are whether profits and losses of the petitioner resulting from purchases and sales of corn futures are capital gains and losses within the meaning of section 117 and, second, whether the wash sales provisions of section 118 apply to those transactions.
FINDINGS OF FACT.
The petitioner filed a consolidated corporate...
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