Robert G. Leslie and Marilyn B. Leslie - Page 36

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          are not entitled to an additional deduction for their "net" loss            
          in excess of straddle gains.                                                
          Increased Interest Under Section 6621(c)                                    
               Respondent seeks increased interest from petitioners pur-              
          suant to section 6621(c).  Rule 142(a).                                     
               Section 6621(c) applies where the Commissioner has estab-              
          lished that there is an underpayment of at least $1,000 in any              
          taxable year "attributable to 1 or more tax motivated trans-                
          actions".  Sec. 6621(c)(2).  Section 6621(c)(3)(A)(iii) specifi-            
          cally includes any straddle as a tax-motivated transaction.                 
          Thus, since petitioner's Hunter straddle transactions were not              
          entered into for profit, they are subject to increased interest             
          under section 6621(c).                                                      
               To reflect the foregoing, and the concessions made by the              
                                                  Decision will be entered            
                                             under Rule 155.                          

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