-2- respective amounts of $983,966.13 and $2,338.90, and additional interest for 1980 pursuant to section 6621(c).1 Pursuant to an amended answer, respondent asserts that petitioners are liable for additional interest for 1976 pursuant to section 6621(c), and additions to tax for 1976 and 1980 pursuant to section 6653(a) in the respective amounts of $49,198 and $117. This case involves petitioner Theodore A. Andros' investment in an options-spreads and futures-trading partnership, Tandrill Associates (Tandrill). It is part of the Arbitrage Management tax litigation project. The deficiencies result from respondent’s disallowance of Theodore A. Andros’ allocable share of partnership losses from: (1) 1979 option spread transactions involving Government securities, and (2) 1979 and 1980 futures transactions involving commodities and Government securities. The deficiency for 1976 results from respondent's reduction in petitioners' net operating loss carryback to that year from 1979. The issues for decision are: (1) Whether respondent properly disallowed petitioners’ allocable share of Tandrill’s losses for 1979 and 1980, pursuant to section 165(c)(2); the resolution of this issue turns on whether the underlying partnership transactions 1 Pursuant to the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1151(c)(1), 100 Stat. 2744, former sec. 6621(d) was redesignated as sec. 6621(c). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011