Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined deficiencies in petitioners' 1980 and 1981 Federal income tax of $4,288 and $1,178, respectively. The sole issue for decision is whether the losses realized by petitioners from trading commodity futures are capital losses which are subject to the limitation set forth in section 1211, or whether they are allowed as a deduction from gross income without limitation. All section references...
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