-14-
Conclusion
We conclude as a matter of law that petitioners and SPK each
failed to make effective mark-to-market elections under section
475(f) for either tax year 2000 or tax year 2001. Accordingly,
we shall grant respondent’s motion for partial summary judgment
and deny petitioners’ motion for partial summary judgment.
To reflect the foregoing,
An appropriate
order will be issued.
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Last modified: May 25, 2011