OPINION
DAVID R. THOMPSON, Circuit Judge:
On their 1976 tax return Milton I. Schwartz and Nina Schwartz reported an ordinary loss of $208,675. This loss was generated by an options straddle. The Schwartzes reported the other end of the straddle, a capital gain of $180,840, on their 1978 tax return.
The tax court disallowed the 1976 deduction in 1983, on the ground the straddle was a sham transaction. The Schwartzes paid the resulting deficiency in...
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