- 2 - 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 withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011