- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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