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10. The partnership’s primary purpose was for the
creation of tax losses. The tax losses reported
in the 1999 tax year are straddle transactions as
defined by IRC 1092. As such the losses are sub-
ject to offsetting of the unrecognized gains re-
ported in the 2000 tax year. Additionally, the
partnership is disregarded for federal tax pur-
poses with all transactions being reversed and
previously reported inflated basis if the partners
relating to contribution of offsetting long and
short currency positions are disregarded along
with reported capital losses, investment interest
expense, distributed property and capital contri-
butions reversed in their entirety and all trans-
actions are treated as having been engaged in by
the partners directly. [Reproduced literally.]
Petitioners in these cases timely filed petitions in re-
sponse to the respective notices of deficiency that respondent
issued to them. In those respective petitions, petitioners
alleged in pertinent part that petitioners invoked “the jurisdic-
tion of this Court primarily for the purpose of confirming that
the Notice [of deficiency] is invalid and no jurisdiction exists”
and that “The adjustments and penalties in the Notice [of defi-
ciency] constitute partnership and/or affected items * * * under
Code Sections 6221 and 6231.”6 Petitioners further alleged in
pertinent part in the respective petitions in these cases:
e. No partnership proceeding has yet been
commenced under Section 6226, much less
concluded.
f. On the same day Respondent issued the
6For convenience, we quote from the petition filed in the
case at docket No. 24289-05. That petition is virtually the same
as the respective petitions filed in the cases at docket Nos.
24297-05 and 24301-05.
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