George C. Scrimshaw and Erna C. Scrimshaw - Page 5

                                         -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...)           




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