Gerald Jacoby and Arlene Jacoby - Page 12

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            investment this tax credit relates.  When petitioner reviewed the                             
            1979 Form 1040, the deductions related to the tax shelters had no                             
            meaning to her, and she did not understand the financial                                      
            consequences of the tax shelter investments.                                                  
                  For the taxable year 1980, Gerald claimed a deduction of                                
            $52,110 attributable to the investment in Power Control.                                      
                  Respondent disallowed the aforementioned deductions and                                 
            investment tax credits attributable to the tax shelters, and the                              
            Jacobys filed a petition in this Court.                                                       
                  In 1992, Gerald and respondent entered into a stipulation of                            
            settlement.  For the taxable year 1978, Gerald conceded that he                               
            was not entitled to any loss attributable to Hawk Mining, Mason                               
            Coal, or T.A.B. Production.  Gerald also conceded that he was not                             
            entitled to the investment tax credit claimed for 1978.                                       
            Respondent conceded that Gerald was entitled to a $40,000 loss                                
            resulting from Masada Press, Ltd., that amount being equal to his                             
            cash investment.  For the taxable year 1979, Gerald conceded that                             
            he was not entitled to any loss attributable to Hawk Mining, or                               
            Masada Press, Ltd.  Gerald also conceded that he was not entitled                             
            to the investment tax credit claimed for 1979.  Respondent                                    
            conceded that Gerald was entitled to a $35,617 loss resulting                                 
            from Power Control.  For the taxable year 1980, Gerald conceded                               
            that he was not entitled to any loss attributable to Power                                    
            Control.  Gerald conceded that the deficiencies for the taxable                               






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