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BOSWELL v. COMMISSIONER

Docket Nos. 28059-85, 29428-85.

91 T.C. 151 (1988)

WILLIAM R. BOSWELL AND JUDY M. BOSWELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT WILLIAM R. BOSWELL AND AGNES C. BOSWELL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 26, 1988.

Attorney(s) appearing for the Case

Robert E. Panoff, for the petitioners.

Theodore J. Kletnick and Nancy B. Romano, for the respondent.

OPINION

SWIFT, Judge:

This matter is before the Court on the parties' cross-motions for summary judgment. The stipulated legal issue for decision concerns the test for determining whether commodity straddle transactions were entered into for profit within the meaning of section 108(a) of the Tax Reform Act of 1984, Pub. L. 98-369, 98 Stat. 494, 630, as amended by section 1808(d) of the Tax Reform Act of 1986...

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