-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
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