Gary K. Bielfeldt and Carlotta J. Bielfeldt v. Commissioner of Internal Revenue

POSNER, Circuit Judge.

Gary Bielfeldt (and his wife, but she is a party only by virtue of having filed a joint return with her husband), a large trader in U.S. Treasury notes and bonds, seeks to overturn a decision by the Tax Court denying him the right to offset immense trading losses that he incurred in the 1980s against all but $3,000 a year in ordinary income. He claims to be not a trader but a dealer and that the losses he incurred in the sale of the Treasury securities were losses connected with his dealer’s “stock in trade”; such losses, even when they result as his did from the sale of…