United States Tax Court February 24, 1994, Docket Nos. 6197-84, 15748-84, 29586-84, 31737-84, 37132-84, 5676-85, 29996-85, 41809-85, 39519-86, 45975-86, 29527-87, 27523-88, 5214-89, 22733-90 (Alling v. Commissioner)

lead-opinion

OPINION

Tannenwald, Judge:

The parties having settled all but one issue, this case comes before the Court fully stipulated under Rule 1222 by certain petitioners, on the issue of the tax treatment of the gains in the years involved herein from commodity tax straddles where the losses from those strad-dies were improperly deducted in the previous year but cannot be disallowed due to