Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a $65,815.16 deficiency in petitioners' Federal income taxes for the 1979 taxable year and a $117,837.63 deficiency for the 1980 taxable year. The issue is whether petitioner's losses from soybean future straddles are allowable under section 108 of the Tax Reform Act of 1984, Pub. L. 98-369, 98 Stat. 494, 630, as amended by section 1808(d) of the Tax Reform Act of 1986, Pub. L. 99...
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