Robert G. Leslie and Marilyn B. Leslie - Page 2

                                                                  - 2 -                                                                       
                1981               49,501              1                2,475                   1               --                            
                1982             366,677               1               18,334                   1           $91,669                           
                1To be determined.                                                                                                            
                         All section references are to the Internal Revenue Code in                                                           
                effect for the taxable years in issue, and all Rule references                                                                
                are to the Tax Court Rules of Practice and Procedure, unless                                                                  
                otherwise indicated.                                                                                                          
                         This case involves Robert G. Leslie's (petitioner's) invest-                                                         
                ments in gold straddle transactions through the futures commis-                                                               
                sion merchant F.G. Hunter & Associates (Hunter).  This is the                                                                 
                same Hunter tax straddle program that was at issue in Ewing v.                                                                
                Commissioner, 91 T.C. 396 (1988), affd. without published opinion                                                             
                940 F.2d 1534 (9th Cir. 1991).                                                                                                
                         On August 30, 1993, respondent filed a Motion for Order to                                                           
                Show Cause why petitioners' case is different than Ewing v.                                                                   
                Commissioner, supra.  On October 18, 1993, petitioners filed                                                                  
                Petitioners' Response To Order To Show Cause.  In their response,                                                             
                petitioners submit that their primary motive for engaging in gold                                                             
                futures transactions with Hunter is distinguishable from that of                                                              
                the taxpayers in Ewing v. Commissioner, supra.  Based on peti-                                                                
                tioners' response, on December 6, 1993, this Court issued an                                                                  
                order discharging the order to show cause.  A trial was held                                                                  
                January 10 and 11, 1995, in Los Angeles, California, to resolve                                                               
                the following issues for decision:                                                                                            







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