Respondent determined a deficiency of $3,127.56 in petitioners' income tax for the calendar year 1950. The issue presented is whether net losses, realized in 1948 by the partnership of which Albert Kurtin was a member, from transactions in butter futures resulted from hedging transactions and are hence allowable as part of a net operating loss carryover to petitioners' 1950 income.
FINDINGS OF FACT.
Some of the facts have been stipulated and are hereby found...
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