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HIRSCH v. COMMISSIONER

Docket No. 13984-80.

46 T.C.M. 559 (1983)

T.C. Memo. 1983-371

Estate of Eric D. Hirsch, Deceased, Leah A. Hirsch, Executrix, and Leah A. Hirsch v. Commissioner.

United States Tax Court.

Filed June 22, 1983.

Attorney(s) appearing for the Case

Ronald S. Borod and Martin H. Aussenberg, P.O. Box 3070, Memphis, Tenn., for the petitioners. Isham B. Bradley, Robert B. Nadler and Vallie C. Brooks, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1976 in the amount of $320,114.81. Due to concessions,1 the principal issue relates to whether or not petitioners incurred short-term capital losses from trading in commodity futures in the years 1973 through 1975 in excess of the amount allowed by respondent to be carried forward to the...

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