-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.
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