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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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