(in response to Tax Court's opinion in Shiekh v. Comr., T.C. Memo. 2012-126, IRS points out that court decision could be incorrectly interpreted as stating that capital gain and ordinary losses offset each other for tax reporting purposes and for purposes of calculating amount of tax due outside scope and context of I.R.C. Sec. 469(d)(1); under I.R.C. Sec. 469 does not require offsetting of capital gain with ordinary losses for other tax purposes).