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KRUMHORN v. COMMISSIONER

Docket No. 4397-90.

103 T.C. 29 (1994)

MORRIS KRUMHORN AND ADRIAN KRUMHORN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 19, 1994.

Attorney(s) appearing for the Case

Robert J. Paley and Peter C. Woodford, for petitioners.

George B. Collins, for petitioner Adrian Krumhorn.

Alan M. Jacobson and Jan E. Lamartine, for respondent.

RUWE, Judge:

Respondent determined deficiencies in petitioners' 1978 and 1979 Federal income taxes in the respective amounts of $2,801,888 and $186,585, plus an addition to tax for the taxable year 1978 in the amount of $140,094, pursuant to section 6653(a).1

After concessions, the issues for decision are: (1) Whether petitioners properly deducted capital losses from purported commodities transactions on their 1978 joint...

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