Dwight E. and Leslie E. Lee - Page 2

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            The Court agrees with and adopts the opinion of the Special Trial                         
            Judge, which is set forth below.                                                          
                              OPINION OF THE SPECIAL TRIAL JUDGE                                      
                  PANUTHOS, Chief Special Trial Judge:  Respondent determined                         
            deficiencies in petitioners' Federal income taxes for the taxable                         
            years 1976 through 1980 as follows:                                                       
                        Docket No.        Year        Deficiency                                      
                        8043-84           1978        $26,811.00                                      
                        43467-85          1977        33,278.26                                       
                        32625-88          1976        133.00                                          
                                          1979        4,046.00                                        
                                          1980        622.00                                          
                  These cases were submitted by the parties fully stipulated.                         
            The three dockets have a long history which we will briefly                               
            review.  One of the issues in all three dockets relates to                                
            petitioners' participation in transactions with Futures Trading,                          
            Inc. ((FTI)/Merit Securities, Inc. (Merit)).  In four                                     
            consolidated cases, Seykota v. Commissioner, T.C. Memo. 1991-234,                         
            supplemented by T.C. Memo. 1991-541, we addressed issues                                  
            concerning the various FTI/Merit transactions.  Petitioners were                          
            not parties to those cases.  The decisions in those cases are                             
            final.                                                                                    
                  On January 11, 1993, a stipulation of settled issues was                            
            filed in all three dockets.  The parties stipulated to all issues                         
            except one which was described as follows:                                                

            (...continued)                                                                            
            references are to the Tax Court Rules of Practice and Procedure.                          




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