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the petitioners' interest in Securities Arbitrage Co.
for all years.
2. Adjustments to the petitioners' income tax
liabilities for the taxable years involved herein which
relate, directly or indirectly, to Securities Arbitrage
Co. will be determined by the terms of the agreement in
Exhibit A. Such adjustments will be incorporated in a
final decision to be entered by this Court for Docket
No. 17775-87.
In the Form 906, Closing Agreement On Final Determination
Covering Specific Matters (the Closing Agreement), attached to
the Stipulation, the parties agreed to the following pertinent
matters:
WHEREAS, an issue exists between the parties as to
whether taxpayers are entitled to deduct losses as a
result of their Securities Arbitrage Co. investment,
WHEREAS, an issue exists between the parties as to
whether taxpayers realized income or gains as a result
of their investment,
WHEREAS, the parties wish to determine with
finality the treatment for Federal income tax purposes
of any losses incurred and the amount, if any, of
income and gains realized by taxpayers as a result of
their investment in Securities Arbitrage Co.
partnership.
NOW IT IS HEREBY DETERMINED AND AGREED, for
Federal income tax purposes that:
1. Taxpayers are not entitled to deductions,
losses or credits nor are they required to report
income or gains as a result of their investment in
Securities Arbitrage Co. partnership except as provided
herein.
* * * * * * *
3. As a result of the investment in Securities
Arbitrage Co. partnership, taxpayers are entitled to
deductions or losses as follows:
* * * * * * *
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Last modified: May 25, 2011