Dwight E. and Leslie E. Lee - Page 3

                                                - 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