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TWAY v. COMMISSIONER

Docket No. 4767-87.

65 T.C.M. 2655 (1993)

T.C. Memo. 1993-212

Jack C. and Phyllis Tway v. Commissioner.

United States Tax Court.

Filed May 17, 1993.

Attorney(s) appearing for the Case

Eugene Chester, 20 Exchange Place, New York, N.Y., and James H. Kenworthy, for the petitioners. Osmun R. Latrobe, for the respondent.

Memorandum Findings of Fact and Opinion

WHALEN, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

 Tax Year Ended                     Deficiency

December 31, 1979 ...............   $393,009.06
December 31, 1980 ...............     25,043.13

The principal issue for decision is whether the pre-1981 losses realized by petitioners from certain transactions involving silver...

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