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KOVNER v. COMMISSIONER

Docket No. 39751-85.

94 T.C. 893 (1990)

RICHARD KOVNER AND JOYCE KOVNER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 20, 1990.

Attorney(s) appearing for the Case

Larry Kars, for the petitioners.

William F. Halley and Michael R. Rizzuto, for the respondent.

OPINION

COLVIN, Judge:

The sole issue for decision is whether petitioner Richard Kovner was a "commodities dealer in the trading of commodities" within the meaning of section 108(b) of the Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat. 630, as amended by section 1808(d) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2817. As described below, we hold that petitioner was not a "commodities dealer in the trading of commodities" for...

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