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(1) Whether certain transactions in gold futures were
entered into by petitioners for profit. We hold that they were
not.
(2) Whether fees paid by petitioners with respect to such
transactions are deductible. We hold that they are not.
(3) Whether petitioners are entitled to a deduction for the
taxable year 1982 for the amount by which the Hunter straddle
losses for the years at issue exceed the straddle gains for the
years at issue. We hold that they are not.
(4) Whether petitioners, with regard to the Hunter straddle
transactions, are liable for increased interest pursuant to
section 6621(d). We hold that they are.
Respondent concedes that, based on the holding in Ewing v.
Commissioner, supra, petitioners are not liable for additions to
tax pursuant to section 6653(a)(1) and (2). Respondent further
concedes that petitioners are not subject to an addition to tax
for the taxable year 1982 pursuant to section 6661.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation and exhibits associated therewith are incorpo-
rated herein by reference.
At the time petition was filed, petitioners resided in Santa
Paula, California. Petitioners' joint Federal income tax returns
for the years in issue were filed with the Office of the Internal
Revenue Service at Fresno, California. Petitioners' returns were
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