- 18 - 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 thePage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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