- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Gary K. Bielfeldt and Carlotta J. Bielfeldt petitioned the Court to redetermine respondent's determination of deficiencies in, and additions to, their 1984 through 1988 Federal income taxes. Respondent determined the following deficiencies and additions thereto: Additions to Tax Year Deficiency Sec. 6653(a)(1) Sec. 6661 1984 --- $32,514 --- 1985 $5,013,651 1,280,929 $1,253,413 1986 19,342,834 967,142 4,835,709 1987 6,871,323 343,566 1,717,831 1988 2,523,008 126,150 630,752 Respondent also determined that petitioners are liable for the time-sensitive addition to tax under section 6653(a)(2) for each of the taxable years from 1984 through 1987. Following the trial of one of the issues arising in this case, we must decide whether gains and losses realized by Gary K. Bielfeldt (petitioner) on the disposition of U.S. Treasury securities (Treasury securities) are ordinary or capital. We hold they are capital. Unless otherwise stated, section references are to the Internal Revenue Code in effect for the relevant years. FINDINGS OF FACT I. Overview Some facts have been stipulated and are so found. The stipulated facts and exhibits submitted therewith are incorporated herein by this reference. Petitioner and Ms.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011