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MILLER v. COMMISSIONER

Docket No. 20724-83.

84 T.C. 827 (1985)

GILBERT R. MILLER AND RITA MILLER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 13, 1985.

Attorney(s) appearing for the Case

William S. Huff, Charles A. Ramunno, and Bruce N. Lemons, for the petitioners.

Theodore J. Kletnick and William F. Garrow, for the respondent.

WHITAKER, Judge:

Respondent determined a deficiency in income tax for petitioners' 1979 taxable year in the amount of $104,236. Due to concessions, the sole issue for determination is the deductibility of short-term losses in the amount of $103,325 from trading in commodity futures straddles claimed on Schedule D of petitioners' income tax return.

FINDINGS OF FACT

Some of the facts have been stipulated...

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