MICHELSON v. C.I.R.

No. 90-9020.

951 F.2d 288 (1991)

Douglas J. MICHELSON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

December 18, 1991.


Attorney(s) appearing for the Case

Matthew E. Cohen and Roy A. Anuskewicz, Jr., Albuquerque, N.M., on the briefs, for petitioner-appellant.

Shirley D. Peterson, Asst. Atty. Gen., and Gary R. Allen, Kenneth L. Greene, and Steven W. Parks, Dept. of Justice, Washington, D.C., on the brief, for respondent-appellee.

Before MCKAY, Chief Judge, and BARRETT and BRORBY, Circuit Judges.


BRORBY, Circuit Judge.

Mr. Michelson appeals from the decisions of the United States Tax Court entered July 26, 1990, determining deficiencies in his federal income tax for the years 1976-81. We affirm those decisions.

The issues in this case derive from the financial losses Mr. Michelson sustained as a result of his transactions involving metal futures (primarily silver) on various commodity exchanges. Characterization of Mr. Michelson's losses was the principal...

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