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Respondent contends that the purpose of the options
transactions was to generate corresponding amounts of ordinary
losses and short-term capital gains in 1979, while the purpose of
the commodity futures transactions was to generate short-term
capital losses in 1979 and long-term capital gains in 1980.
Respondent posits that at the time the transactions were entered
into, Tandrill’s general partners (petitioner and Mr. Illingworth)
expected to realize economic losses rather than economic profits.
According to respondent, petitioner was aware that the economic
consequences of the transactions entered into by Tandrill were de
minimis as compared to their potential tax benefits. On the other
hand, petitioners argue that the transactions at issue were entered
into with both a profit motive and profit potential. We agree with
respondent.
Respondent and petitioners each rely on reports and testimony
of their respective experts. As the trier of fact, we must weigh
the evidence presented by these experts in light of their
demonstrated qualifications as well as all other credible evidence.
Estate of Christ v. Commissioner, 480 F.2d 171, 174 (9th Cir.
1973), affg. 54 T.C. 493 (1970). We are not bound by the opinion of
any expert witness when that opinion is contrary to our own
judgment. Chiu v. Commissioner, 84 T.C. 722, 734 (1985).
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