Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income tax for 1956 and 1957 in the respective amounts of $10,927.45 and $3,366.48 and of $583.06 for 1956 in addition to tax under section 6651(a), I. R. C. 1954. Both parties having made concessions, the sole remaining issue is whether petitioner's losses in commodity futures contracts were deductible in full or only as capital losses under section 1211(b), I. R...
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