- 6 - 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. forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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