- 4 - petitioner maintained the first office in London, England, with a staff of 3 to 5 employees, including one of petitioner’s vice presidents as managing director. From 1987 through 1990, petitioner maintained the second office in Tokyo, Japan, with a staff of 3 or 4 employees, including a managing director who became a vice president of petitioner in 1988. Petitioner maintained the other two offices in New York, New York, and Washington, D.C., with a staff of 2 to 5 employees and 4 to 6 employees, respectively. The New York office also was managed by one of petitioner’s vice presidents. In December 1988, petitioner formed a second limited partnership named P-M-T Limited Partnership (PMT). Petitioner is a 10-percent general partner in PMT, and petitioner’s members and clearing house members collectively own the remaining 90-percent interest as limited partners. PMT was formed to create and license a global electronic system for trading futures and options on futures contracts during the non-trading hours of petitioner’s commodity exchange. Discussion Before 1986, taxpayers who acquired certain machinery and equipment for use in a trade or business were allowed an investment tax credit against their income tax liability in an amount equal to a percentage of the cost of the qualified property. Secs. 38, 46, 48. TRA section 211, 100 Stat. 2166,Page: Previous 1 2 3 4 5 6 7 8 9 Next
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