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LAUREYS v. COMMISSIONER

Docket No. 23490-85.

92 T.C. 101 (1989)

FRANK J. LAUREYS, JR., AND CAROL J. LAUREYS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 25, 1989.

Attorney(s) appearing for the Case

John V. Ryan III, for the petitioners.

Theodore J. Kletnick and Lawrence Blaskopf, for the respondent.

COHEN, Judge:

Respondent determined deficiencies of $310,068 and $171,828 in petitioners' Federal income taxes for 1980 and 1982, respectively, resulting from disallowance of losses claimed by petitioner Frank J. Laureys, Jr. (petitioner), from certain option spread transactions. The questions presented are (1) whether offsetting positions in such option transactions were a "similar arrangement" protecting petitioner...

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