- 3 - 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 SchedulePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007