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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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Last modified: May 25, 2011