Thomas E. and Joan A. Bennett - Page 6

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               During 1981, Thomas E. Bennett (Bennett) was a vice                    
          president at Ingersoll-Rand Company (Ingersoll-Rand).  His                  
          spouse, Joan A. Bennett, was not employed outside the home.                 
          Theodore H. Black (Black) was also a vice president of Ingersoll-           
          Rand during 1981.  His wife, Marilyn F. Black, was not employed             
          outside the home.                                                           
               For their respective investments of $25,000, petitioners               
          Bennett and Black each acquired a 2.605-percent interest in the             
          limited partnership Empire Associates (Empire) during 1981.  As a           
          result of the passthrough from Empire, on their respective 1981             
          Federal income tax returns petitioners each deducted an operating           
          loss in the amount of $20,510 and claimed investment tax credits            
          in the amount of $42,402.  Petitioners Bennett used $22,328 of              
          the claimed credits on their 1981 return and carried back the               
          unused portion of the credits to 1978 and 1979 in the respective            
          amounts of $19,120 and $954.  Respondent disallowed petitioners'            
          claimed deductions and credits related to Empire.  In docket No.            
          31758-85, respondent disallowed petitioners Bennett's claimed               
          deductions related to three previously mentioned partnerships not           
          at issue herein.                                                            
               The facts of the underlying transaction in these cases are             
          substantially identical to those in Provizer v. Commissioner,               
          T.C. Memo. 1992-177, and may be summarized as follows.  In 1981,            
          Packaging Industries, Inc. (PI), manufactured and sold seven                
          Sentinel expanded polyethylene (EPE) recyclers to ECI Corp. for             




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