Gary K. Bielfeldt and Carlotta J. Bielfeldt - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Gary K. Bielfeldt and Carlotta J. Bielfeldt              
          petitioned the Court to redetermine respondent's determination of           
          deficiencies in, and additions to, their 1984 through 1988                  
          Federal income taxes.  Respondent determined the following                  
          deficiencies and additions thereto:                                         
                     Additions to Tax                                                 
               Year    Deficiency    Sec. 6653(a)(1)     Sec. 6661                    
               1984       ---            $32,514            ---                       
               1985    $5,013,651      1,280,929        $1,253,413                    
               1986    19,342,834        967,142         4,835,709                    
               1987     6,871,323        343,566         1,717,831                    
               1988     2,523,008        126,150           630,752                    
          Respondent also determined that petitioners are liable for the              
          time-sensitive addition to tax under section 6653(a)(2) for each            
          of the taxable years from 1984 through 1987.                                
               Following the trial of one of the issues arising in this               
          case, we must decide whether gains and losses realized by Gary K.           
          Bielfeldt (petitioner) on the disposition of U.S. Treasury                  
          securities (Treasury securities) are ordinary or capital.                   
          We hold they are capital.  Unless otherwise stated,                         
          section references are to the Internal Revenue Code in effect for           
          the relevant years.                                                         
                                  FINDINGS OF FACT                                    
          I.  Overview                                                                
               Some facts have been stipulated and are so found.  The                 
          stipulated facts and exhibits submitted therewith are                       
          incorporated herein by this reference.  Petitioner and Ms.                  



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