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trades on only 6 days in the taxable year and generated enough
losses to offset almost completely both his and his wife's
taxable income from other sources. Mr. Resser's pattern of
trading reveals that he received what he sought--tax benefits to
offset other income. Mr. Resser's activities with respect to
account QRF were, fundamentally, a tax shelter. As such, the
losses attributable thereto were not deductible under well-
settled legal principles. Accordingly, the deduction derived
from the account QRF option spread losses constitutes a grossly
erroneous item as required by section 6013(e)(1)(B).
We have considered all of respondent's arguments and, to the
extent not discussed above, find them to be without merit.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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