David C. Wilson - Page 18

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          respective investments in Clearwater.  The table below shows the            
          amounts of credits related to Clearwater available to petitioners           
          and the amounts of petitioners' investments in Clearwater through           
          EI.                                                                         
                              Investment Tax and       Investment                     
               Petitioners    Business Energy Credits  in Clearwater1                 
               Wilson              $57,898             $33,533                        
               Sorey          19,314                   11,179                         
               1Calculated as follows:                                                
               EI's Investment in Clearwater     Wilson's Share of EI                 
          $350,000              x        9.581%          =$33,533                     
               EI's Investment in Clearwater  x  Sorey's Share of EI                  
          $350,000                       3.194%          =$11,179                     
          The total benefits available to petitioners were not used                   
          entirely on their 1981 tax returns.  Wilson deducted an operating           
          loss of $26,830, attributable to the Clearwater investment, and             
          used $24,545 of the credits on his 1981 return.  The record does            
          not disclose Wilson's use of the additional credits, whether for            
          carryover to later years in which he continued employment as a              
          professional football player or otherwise.  Sorey used $4,805 of            
          the claimed credits on his 1981 return and carried back $10,021             
          of credits to 1978 and $4,488 of credits to 1979.  Like the                 
          taxpayers in Provizer v. Commissioner, T.C. Memo. 1992-177,                 
          "except for a few weeks at the beginning, petitioners [Wilson and           
          Sorey] never had any money in the [Clearwater] deal."  In light             
          of the large tax benefits claimed on petitioners' 1981 Federal              
          income tax returns, and available for prompt use on their other             
          tax returns, we conclude that further investigation of the                  




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