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commodity futures that he traded. See United States v.
Rogers, supra; Hoover Co. v. Commissioner, supra; Wool
Distrib. Corp. v. Commissioner, 34 T.C. 323 (1960).
Indeed, petitioner has not even identified the specific
commodities that were the subject of his day trades. We
perceive no necessary relationship between the price of
petitioner's manuscript and the price of the commodities
that petitioner traded such as to qualify as a hedge.
Thus, we reject petitioner's argument that the commodity
futures that he traded during the years in issue were
hedges against the loss in value of his manuscript.
Accordingly, we reject petitioner's argument that his
losses from trading commodity futures during 1989 and 1990
are deductible as ordinary losses.
Before leaving this issue, we note that petitioner
labeled the deduction of his trading losses in each of the
years in issue as "Research & Experimentation to Improve
Trading System Formula for Sale". We also note that the
petition states that the losses are deductible under
section 1.174-1, Income Tax Regs., as "research &
development expenses". However, in his post-trial brief,
petitioner does not claim that the subject losses are
deductible as research and experimental expenditures under
section 174. Thus, petitioner has abandoned this argument.
Money v. Commissioner, 89 T.C. 46, 48 (1987); Alexander v.
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