Bernhard F. and Cynthia G. Manko - Page 5

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          1983.  In other words, we must determine whether the blanket                
          settlement offer that petitioners accepted was an offer to settle           
          an issue (i.e., the deductibility of Arbitrage Management losses)           
          or a specific taxable year.                                                 
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulation of facts and the attached exhibits            
          are incorporated herein by this reference.  We also incorporate             
          herein the facts enumerated in Manko I.  For a better understanding         
          of this case, we repeat a portion of those facts.                           
               Petitioners resided in Lighthouse Point, Florida, at the time          
          they filed their petition. They timely filed joint Federal income           
          tax returns for 1979 through 1983.                                          
               A.  Arbitrage Management                                               
               Arbitrage Management began operations in the mid-to-late               
          1970's.  From 1978 through 1981, Arbitrage Management dealt                 
          primarily in the acquisition of straddle positions in U.S. Treasury         
          bill options. Beginning in 1982, Arbitrage Management dealt                 
          primarily in the acquisition of U.S. Government securities financed         
          by repurchase agreements.                                                   
               Petitioner served as a principal of Arbitrage Management and           
          a general partner of limited partnerships that invested in                  
          Government securities acquired through Arbitrage Management                 
          (Arbitrage Management partnerships).  On their 1978 through 1983            
          tax returns, petitioners deducted petitioner's distributive shares          





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