-4-
September 2001, respectively. Petitioners and SPK attached
copies of the Forms 3115 they had filed to their returns for
2000. The returns for 2000 and 2001 reflected that petitioners
and SPK each used the mark-to-market method of accounting for
their securities trading activity. Petitioners and SPK each
reported ordinary losses for both years. Petitioners reported
their own ordinary losses as well as their 100-percent share of
SPK’s ordinary losses for both years, totaling $2,333,698 in 2000
and $2,985,149 in 2001.
Petitioners claimed a net operating loss for 2001 due to the
ordinary securities trading losses. Petitioners seek to carry
this net operating loss back to tax years 1996 through 1999
pursuant to section 172. Petitioners accordingly applied for
tentative refunds for 1996, 1997, 1998, and 1999, which
respondent disallowed.
Petitioners’ and SPK’s Requests for Letter Rulings
Petitioners and SPK both requested that respondent issue
letter rulings concerning the effectiveness of their mark-to-
market election under section 475(f) for 2000. Petitioners and
SPK also stated in their ruling requests that they should be
granted administrative relief from a late election under section
9100. Petitioners and SPK each withdrew their requests for
letter rulings when they learned that the pending letter ruling
requests would be decided adversely to them.
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