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c. 1980 $ 18,898.00 ($12,598,856 x 15% x taxpayers
interest in Securities Arbitrage
Co. partnership as an ordinary
deduction);
d. 1980 $ 80,906.00 (180% of actual cash
investment in Securities
Arbitrage Co. partnership as
an ordinary deduction.)
* * * * * * *
6. During * * * 1980 * * * taxpayers realized
and are required to report income as follows, as a
result of the Securities Arbitrage Co. partnership
investment:
* * * * * * *
b. 1980 $ 38,305.00 ([$20,060,852 x 15% +
$821,457] x taxpayers'
interest in Securities
Arbitrage Co. partnership as
short-term gain);
* * * * * * *
7. Any money or other property received by the
taxpayers, directly or indirectly, as a result of the
investment in Securities Arbitrage Co. partnership
shall constitute ordinary income in the year received.
8. The taxpayers have executed concurrently with
this agreement an agreement as an investor in the
Securities Arbitrage Co. partnership pursuant to I.R.C.
Section 6224(c) agreeing that Securities Arbitrage Co.
partnership had no gains, losses, deductions or credits
for the taxable year 1981 through 1985, inclusive.
After the Stipulation was filed, respondent mailed to
petitioners a proposed Decision and overpayment Stipulation,
together with the revised Computations. Respondent, by letter,
twice asked petitioners to execute and return the proposed
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