Alex and Liset Meruelo v. Commissioner

132 T.C. No. 18

UNITED STATES TAX COURT ALEX AND LISET MERUELO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 624-04. Filed June 9, 2009. R issued Ps a notice of deficiency (NOD) for 1999 that contained determinations related to an entity subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA),

Pub. L. 97-248, sec. 401, 96 Stat. 648. On their 1999 Federal income tax return, Ps claimed a deduction for a $4,538,844 loss that reportedly passed through to them from a partnership they identified as M. M was…