-5-
Six Star Cablevision Management Corporation that were disallowed in
the statutory notice of deficiency. As part of the computation,
petitioners were entitled to claim a loss of $12,750.00 in 1978;
(2) The adjustments in the notice of deficiency for options and
futures transactions with Gardner Lohmann Limited and Amalgamated
Metal Trading Limited were computed based upon the Court's opinion
in the case of Glass v. Commissioner, 87 T.C. 1087 (1987), affd.
sub nom. Keane v. Commissioner, 63 AFTR2d 89-622, 89-1 USTC par.
9134 (9th Cir. 1989) (also affirmed in five other Courts of
Appeals); (3) The Investors Mining Program 77-5 adjustments were
computed based upon the Stipulation of Settlement executed in the
name of Erna C. Scrimshaw, George C. Scrimshaw and petitioners'
then attorney; and (4) Respondent conceded the negligence additions
determined for 1976 through 1979.
On June 20, 1991, the IRS District Counsel's office in New
York mailed petitioners a decision document4 based upon the October
4 The decision document states as follows:
Pursuant to the agreement of the parties
in the above-entitled case, it is
ORDERED AND DECIDED: That there are
deficiencies in income tax due from the
petitioners for the taxable years 1975, 1976,
1977, 1978 and 1979 in the amounts of
$1,929.00, $6,448.00, $5,476.00, $11,776.00
and $8,582.00, respectively;
That there are no additions to tax due
from the petitioners for the taxable years
1976, 1977, 1978, and 1979 under the
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011