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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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