James E. Zurcher - Page 10

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          C.P.A. concluded that petitioner was entitled to ordinary loss              
          treatment.  Under the facts herein, we find that petitioner acted           
          in good faith and with reasonable cause in reporting the                    
          transaction in the manner that he did.                                      
               We have reached our holdings herein after considering each             
          party's arguments.  To the extent that we have not discussed an             
          argument, we have found it to be irrelevant or without merit.               
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent for the                   
                                             deficiency and for petitioner            
                                             for the accuracy-related                 
                                             penalty.                                 
























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