- 5 - 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: * * * * * * *Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011