- 3 - The only issue remaining in dispute between the parties is whether petitioners are entitled to interest expense deductions claimed in connection with Peng Partners. This issue relates to the Merit project and either will be resolved by the parties or submitted to the Court for resolution. As a result of a continuing dispute as to the proper interpretation of terms of the stipulation, a number of motions were filed and resolved by the Court.2 When cross-motions for orders to show cause were filed in March and April 1996, the Court set these cases for hearing at a session scheduled to take place in New York, New York. The cases were ultimately submitted fully stipulated. Background At the time the petitions were filed, petitioners resided in New York, New York. During 1977 through 1980, petitioner Dwight E. Lee (petitioner) was a partner in an entity known as Peng Partners. During those years, Peng Partners participated in "Arbitrage and Carry" (A/C) transactions promoted by FTI. In 1979 and 1980, Peng Partners also participated in T-Bill options transactions through Merit. This Court has considered both the FTI A/C transactions and the Merit T-Bill options transactions in cases involving Merit Securities. See Seykota v. Commissioner, T.C. Memo. 1991-234, supplemented by T.C. Memo. 1991-541. 2 Other investors also disputed the terms of apparent agreements with respect to transactions with FTI/Merit. See, for example, Lamborn v. Commissioner, T.C. Memo. 1994-515.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011