-3- remained at home to take care of their children until January 1987, when she resumed her nursing career. Petitioners filed joint Federal income tax returns for years 1975 through 1979. On December 3, 1981, respondent sent petitioners a notice of deficiency regarding these years. Pursuant to the notice of deficiency, respondent disallowed losses and deductions petitioners claimed on their 1975-79 returns and determined negligence additions to tax for 1976-79. Respondent's adjustments were made with regard to the losses and deductions petitioners claimed for 1975-79, arising from transactions involving: (1) Investors Mining Program 77-5 in 1977 and 1978; (2) commodity options and futures contracts with Gardner Lohmann Limited and Amalgamated Metal Trading Limited in 1976 and 1977;2 and (3) investments with Six Star Cablevision Management Corp. in 1978 and 1979. (Petitioners' 1975 tax year was involved because of the disallowance of an investment credit claimed to have been generated in 1979 and carried back to 1975.) On February 12, 1982, petitioners filed a petition in this Court, disputing respondent's adjustments in the notice of deficiency and claiming that the period of limitations had expired for petitioners' 1975-77 tax years. 2 Respondent and the Court treated the options and futures contracts with Gardner Lohmann Limited and Amalgamated Metal Trading Limited as part of the "London Options" tax shelter project.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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