- 2 -
1981 49,501 1 2,475 1 --
1982 366,677 1 18,334 1 $91,669
1To be determined.
All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
This case involves Robert G. Leslie's (petitioner's) invest-
ments in gold straddle transactions through the futures commis-
sion merchant F.G. Hunter & Associates (Hunter). This is the
same Hunter tax straddle program that was at issue in Ewing v.
Commissioner, 91 T.C. 396 (1988), affd. without published opinion
940 F.2d 1534 (9th Cir. 1991).
On August 30, 1993, respondent filed a Motion for Order to
Show Cause why petitioners' case is different than Ewing v.
Commissioner, supra. On October 18, 1993, petitioners filed
Petitioners' Response To Order To Show Cause. In their response,
petitioners submit that their primary motive for engaging in gold
futures transactions with Hunter is distinguishable from that of
the taxpayers in Ewing v. Commissioner, supra. Based on peti-
tioners' response, on December 6, 1993, this Court issued an
order discharging the order to show cause. A trial was held
January 10 and 11, 1995, in Los Angeles, California, to resolve
the following issues for decision:
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