Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in petitioners' income tax liability for the year 1980 in the amount of $9,891.90 and for the year 1982 in the amount of $1,381. Due to concessions by both parties, the sole issue for decision is whether the losses incurred by Mr. LaBorde in commodity futures trading in the years 1980 and 1982 are deductible as ordinary losses as claimed by petitioners or as...
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