- 23 - a loss in the amount of $797,500. Petitioner reported the loss as a long-term capital loss. Twenty-five short June 1982 contracts were liquidated by assignment at a gain in the amount of $1,062,125. Petitioner treated the gain as a long-term capital gain. Petitioner liquidated his final positions with Hunter on May 26, 1982. This resulted in an offset loss of $2,814,700 from the remaining long contracts and a gain from the assignment of the remaining short contracts of $3,315,550. The loss was treated by petitioner as a long-term capital loss, and the gain was treated as a long-term capital gain. Petitioners claimed on their 1982 joint Federal income tax returns that the results of their 1982 Hunter trades were net long-term capital gains from the assignment and offset of gold futures contracts in the amount of $1,172,950. OPINION Losses on Straddle Transactions The primary issue in this case is whether petitioners are entitled to deduct losses on the Hunter straddle transactions as claimed on their Federal income tax returns for the taxable years 1980, 1981, and 1982. Resolution of the issue turns on the effect of section 108(a) of the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, 98 Stat. 494, 630, as amended by section 1808(d) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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