- 2 -
agreed to with regard to the tax adjustments in dispute and with
regard to increased interest under section 6621(c). The years
before us in this case are 1979 and 1980.
Stipulations of settlement were filed by the parties on
October 6, 1992, and July 7, 1995, respectively. The
computational dispute between the parties involves an
interpretation of the stipulation of settlement filed on July 7,
1995 (the stipulation).
The stipulation provides, among other things, that
respondent’s adjustments regarding the so-called Arbitrage
Management tax shelter scheme, as those adjustments are set forth
in respondent’s notice of deficiency for 1979 and 1980, are to be
sustained.
Although petitioners’ 1981 and 1982 tax years are closed for
the filing by petitioners of claims for refund and although those
years are not before us in this case, the stipulation provides,
by way of settlement, that petitioners’ income for 1979 is to be
increased by $645,469, which income relates to the netting into
petitioners’ 1979 tax year adjustments pertaining to Arbitrage
Management that arose in 1981 and 1982.
For 1979 and apparently for 1980, petitioners now attempt to
offset against the tax adjustments agreed to in the stipulation
alleged net operating losses (NOL's) of $174,176 and $184,972,
respectively, from petitioners' closed 1981 and 1982 tax years,
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011