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$54,529.65 trading commodity futures in 1989 and 1990,
respectively.
Petitioner received the following gross receipts from
the sale of his manuscript:
Year Gross Receipts
1985 $557.30
1986 --
1987 2,162.00
1988 47,185.80
1989 138,681.46
1990 65,903.70
He reported the gross receipts for Federal income tax
purposes on a Schedule C, Profit or Loss From Business,
attached to his return for each of the above years. For
1989 and 1990, petitioner's Schedules C report that he
received the above gross receipts from a business by the
name of "ED Cullin Commodity Trading Advisory" which was
in the business of "Commodity Trading Advisor/Publishing".
The Schedules C for petitioner's publishing business
for 1989 and 1990 also report deductions for "Research &
Experimentation to Improve Trading System Formula for Sale"
of $101,938.26 and $54,529.65, respectively. These amounts
are the losses that petitioner sustained trading commodity
futures.
In the subject notice of deficiency, respondent
disallowed the deduction of petitioner's commodity trading
losses for 1989 and 1990. The notice states as follows:
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