ALLING v. COMMISSIONER

Docket Nos. 6197-84, 15748-84, 29586-84, 31737-84, 37132-84, 5676-85, 29996-85, 41809-85, 39519-86, 45975-86, 29527-87, 27523-88, 5214-89, 22733-90.

102 T.C. 323 (1994)

FREDERICK A. AND MARTHA G. ALLING, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 24, 1994.


Attorney(s) appearing for the Case

Hugh Janow, for petitioners.

Theodore J. Kletnick and Maria T. Stabile, for respondent.


OPINION

TANNENWALD, Judge:

The parties having settled all but one issue, this case comes before the Court fully stipulated under Rule 1222 by certain petitioners, on the issue of the tax treatment of the gains in the years involved herein from commodity tax straddles where the losses from those straddles were improperly deducted in the previous year but cannot be disallowed due...

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