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
OPINION
Goeke, Judge:
On March 30, 2007, respondent mailed a notice of final partnership administrative adjustment (FPAA) to the tax matters partner (tmp) for Gaughf Properties, L.P. (Gaughf Properties), concerning the tax year ended (tye) December 27, 1999. The FPAA reflected respondent’s determination that Gaughf Properties failed to recognize $4,455,000 in gross income resulting from the expiration of a currency option (described further infra). Some issues in the case have been separated for purposes of trial and opinion. The issues for decision are:1(1) whether, on March 30, 2007, the…
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3Cited by3 opinions
- Gaughf Properties, L.P. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2013
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