Lowell L. and Marilyn A. Robertson - Page 60




                                       - 60 -                                         
                  Petitioners object to respondent's computation of the               
             deficiency in, and additions to, petitioners' 1984 tax on                
             two grounds.  First, respondent failed to give petitioners               
             any credit in 1984 for taxes paid with respect to the                    
             income from the Roscrea Trust reported on their returns for              
             the years 1987 through 1990. Petitioners refer to income                 
             from the Trust that was reported on their returns for the                
             years 1987 through 1990 as "phantom income".  Second,                    
             respondent failed to recognize in computing petitioners'                 
             1984 taxes the "economic loss" of $57,420 that petitioners               
             suffered by reason of their cash investment in the Roscrea               
             Trust.                                                                   
                  Petitioners ask the Court to order respondent to take               
             those items into account (i.e., "phantom income" reported                
             for the years 1987 through 1990 and petitioners' cash                    
             investment) in computing their liability for taxes,                      
             interest, additions, and penalties with respect to the                   
             year in issue in this case, 1984, and the years in issue                 
             in other docketed cases, 1982, 1983, and 1985.  According                
             to petitioners, their request "is consistent with this                   
             Court's inherent powers, general equitable principles, and               
             clear Congressional intent--as well as common sense notions              
             of judicial economy and sound tax administration."                       








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