-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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011