Stephen S. Ziegler - Page 3
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tioner invested, as discussed below. During 1995 through 1999,
the years at issue, petitioner practiced law full time with the
law firm of Ziegler, Sagal & Winters, PC, in New York, New York.
During the years at issue, petitioner was a limited partner
of Aldus Green Company (Aldus Green), a limited partnership
formed under the laws of the State of New York. As a limited
partner of Aldus Green, petitioner owned two percent of Aldus
Green’s capital, profits, and losses.
In 1984, Aldus Green purchased and operated certain low-
income rental apartment buildings located in Bronx, New York.
Aldus Green rented apartments in those buildings to low-income
individuals, who received rent subsidies under section 8 of the
United States Housing Act, as amended.
Petitioner filed Form 1040, U.S. Individual Income Tax
Return, for each of his taxable years 1995 through 1999 (peti-
tioner’s returns). In each such return, petitioner claimed in
Schedule E, Supplemental Income and Loss (Schedule E), a loss
attributable to his investment in Aldus Green (petitioner’s
claimed Aldus Green loss) in arriving at “Total partnership and S
corporation income or (loss)” in each such schedule. As a
result, in Schedule E for each of the years at issue, petitioner
claimed a total partnership and S corporation loss. In each of
petitioner’s returns for the years at issue, petitioner offset
the total partnership and S corporation loss claimed in Schedule
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Last modified: November 10, 2007