- 3 - Gateway to GFI and Gateway was dissolved. On December 22, 2000, GFI sold the euro for $20,573. On September 6, 2001, Gateway filed a Form 1065, U.S. Return of Partnership Income, relating to the tax year beginning October 27, 2000, and ending December 21, 2000. The Form 1065 showed distributions of property other than money in the amount of $5,020,000 (i.e., the $5 million paid for the long options and the purchase price of the euro). On June 28, 2001, GFI filed a Form 1120S, U.S. Income Tax Return for an S Corporation, relating to 2000. The Form 1120S showed a $4,999,427 loss relating to foreign currency (i.e., a purported basis of $5,020,000 in the foreign currency and a $20,573 amount realized). On October 22, 2001, petitioner filed his 2000 Federal tax return and reported a net operating loss of $4,146,903 relating to GFI’s foreign currency loss. On August 12, 2002, petitioner filed his 2001 Federal tax return and reported a net operating loss of $4,146,903 and an overall loss of $2,948,966. On June 28, 2004, respondent sent Gateway, GFG, and GFI Notices of Final Partnership Administrative Adjustment (FPAAs) relating to 2000. On November 26, 2004, petitioner filed a petition relating to the FPAA issued to Gateway. The Court, however, dismissed that petition because it was not filed by a proper party. On August 10, 2005, respondent sent petitioner a notice of deficiency relating to 2001. Respondent disallowed petitioner’sPage: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007