- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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