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All section references are to the Internal Revenue Code
as in effect for the years in issue.
After concessions, the issues remaining for decision
are: (1) Whether petitioner's losses from trading
commodity futures are capital or ordinary; and (2) whether
petitioner is liable for the accuracy-related penalties
prescribed by section 6662(a) as determined by respondent
for 1989 and 1990.
FINDINGS OF FACT
The parties have stipulated some of the facts. The
stipulation of facts filed by the parties and the exhibits
attached thereto are incorporated herein by this reference.
Petitioner was a resident of Dunwoody, Georgia, at the time
he filed his petition in this case.
During the years 1985 through 1990, petitioner was
self-employed as a freelance writer and publisher. Prior
to the years in issue, petitioner researched and wrote a
manuscript entitled "The Wall Street Newspaper Daytrading
Strategy". The manuscript describes a mechanical system
for trading commodity futures which focused on the lead
story on the Commodities Page of the Wall Street Journal.
At the time the manuscript was written, there was only one
lead story on the Commodities Page. The manuscript
instructs a reader in how to execute a day trade with
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