Gary K. Bielfeldt and Carlotta J. Bielfeldt - Page 4

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          which petitioner was the controlling partner.2  Respondent's                
          audit of petitioner ended on April 22, 1991, with the issuance to           
          him of a 30-day letter.                                                     
               On July 17, 1991, petitioner amended his 1985 through 1988             
          tax returns to assert therein that he was a dealer in Treasury              
          securities, and that he was entitled to income tax refunds                  
          resulting from reclassifying his gains and losses as ordinary.              
          On January 11, 1996, respondent issued to petitioner a notice of            
          deficiency that, in relevant part, disallowed the refund claims             
          on the amended returns on the basis of respondent's determination           
          that petitioner was not a dealer in Treasury securities.  In this           
          proceeding, petitioner claims the following income tax refunds on           
          the basis of his assertion that he was a dealer:                            
                              Year             Refund                                 
                              1984      $3,202,380                                    
                              1985           19,781,480                               
                              1986           39,160,798                               
                              1987           16,232,812                               
                              1988           6,658,075                                

          II.  Treasury Securities Cash Market                                        
               The Treasury securities cash market consists of bills,                 
          notes, and bonds issued by the Department of the Treasury                   
          (Treasury).  Treasury bills (T-bills) are issued in 3-month,                
          6-month, or 1-year maturities.  T-bills are non-interest-bearing            


               2 BL&H's partnership agreement was amended on Dec. 7, 1985,            
          to change BL&H's name to B&C as of Jan. 1, 1986.  Both BL&H and             
          B&C filed Forms 1065, U.S. Partnership Return of Income.                    
          Hereinafter, we refer to BL&H as B&C.                                       


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