Gaughf Props., L.P. v. Comm'r
United States Tax Court
A partnership entered a complicated series of transactions involving currency options and stock trades. Two LLCs and an S corporation also took part in the transactions. All four entities were formed in 1999 and were owned either directly or indirectly by H and/or W. The transactions were intended to yield losses that would offset substantial unrealized gains in stock owned by H by inflating outside basis in the partnership.
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A partnership entered a complicated series of transactions involving currency options and stock trades. Two LLCs and an S corporation also took part in the transactions. All four entities were formed in 1999 and were owned either directly or indirectly by H and/or W. The transactions were intended to yield losses that would offset substantial unrealized gains in stock owned by H by inflating outside basis in the partnership. H and W were indirect partners of the partnership but did not list certain information identifying themselves as partners on the partnership's 1999 tax return. R was in…
1Opinion of the Court
GAUGHF PROPERTIES, L.P., BALAZS VENTURES, LLC, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gaughf Props., L.P. v. Comm'r
Docket No. 18298-07.
United States Tax Court
139 T.C. 219; 2012 U.S. Tax Ct. LEXIS 31; 139 T.C. No. 7;
September 10, 2012, Filed
An appropriate order will be issued as to the period of limitations issue.
A partnership entered a complicated series of transactions involving currency options and stock trades. Two LLCs and an S corporation also took part in the transactions. All four entities were formed in 1999 and were…
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