BOOCHEVER, Circuit Judge:
The Wehrlys appeal the denial of a tax refund relating to straddle investments in forward contracts for government mortgage certificates. The court instructed the jury that losses on one leg of the straddle were deductible under Internal Revenue Code § 165(c)(2), 26 U.S.C. § 165(c)(2) (1982), only if the Wehrlys' primary motive for entering into the transactions was to make a profit.
We reverse and remand, holding that the...
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