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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