Robert G. Leslie and Marilyn B. Leslie - Page 3

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               (1)  Whether certain transactions in gold futures were                 
          entered into by petitioners for profit.  We hold that they were             
               (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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