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KOZIKOWSKI v. COMMISSIONER

Docket No. 7666-83.

52 T.C.M. 148 (1986)

T.C. Memo. 1986-364

Arnold J. Kozikowski and Sharon L. Kozikowski v. Commissioner.

United States Tax Court.

Filed August 11, 1986.

Attorney(s) appearing for the Case

Arnold J. Kozikowski, pro se, Fraser, Mich. Oksana O. Xenos, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1979 in the amount of $8,441 and an addition to tax under section 6653(a)1 in the amount of $422. After concessions, the issues are: (1) whether a loss realized by petitioners' wholly owned partnership from the sale of commodity futures is ordinary or capital; (2) whether petitioners have satisfied...

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