McGUIRE v. COMMISSIONER

Docket No. 28105-86.

60 T.C.M. 1346 (1990)

T.C. Memo. 1990-610

John A. and Susan C. McGuire v. Commissioner.

United States Tax Court.

Filed December 4, 1990.


Attorney(s) appearing for the Case

John A. McGuire, pro se. Jeffery N. Kelm and Albert A. Balboni, for the respondent.


Memorandum Opinion

POWELL, Special Trial Judge:

This case involves deductions claimed for losses incurred in certain straddle transactions conducted with an entity known as Hillcrest Securities.1 Petitioners concede that the transactions were not bona fide; they contend, however, that the Court lacks jurisdiction because the notice of deficiency was invalid under the reasoning of Scar v. Commissioner [87-1 USTC ¶...

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