Theodore A. Andros and Joan B. Andros - Page 3

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          were entered into primarily for profit; (2) whether petitioners are         
          liable for additions to tax for negligence or intentional disregard         
          of rules or regulations for 1976 and 1980; and (3) whether                  
          petitioners are liable for additional interest for 1976 and 1980.           
               We find that the underlying options-spreads and futures-               
          trading transactions by Tandrill were not entered into primarily            
          for profit, and we therefore hold that respondent properly                  
          disallowed petitioners’ allocable share of Tandrill’s losses for            
          1979 and 1980.  We further hold that petitioners are not liable for         
          additions to tax for negligence or intentional disregard of rules           
          or regulations for 1976 and 1980, but that they are liable for              
          additional interest for 1976 and 1980.                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulations of facts and the attached exhibits           
          are incorporated herein by this reference.                                  
          Background                                                                  
               Petitioners, husband and wife, resided in Key Biscayne,                
          Florida, at the time they filed their petition.  They filed joint           
          Federal income tax returns for all relevant years. In April 1980,           
          petitioners filed a Form 1045, Application for Tentative Refund,            
          claiming that they were entitled to a net operating loss carryback          
          of $1,766,137 from 1979 to 1976.                                            
               Joan B. Andros is involved in this case by virtue of having            
          filed joint Federal income tax returns with her husband, Theodore           




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