- 2 - affd. 4 F.3d 709 (9th Cir. 1993), Feldman v. Commissioner, T.C. Memo. 1991-353, affd. without published opinion 5 F.3d 536 (9th Cir. 1993), and Garcia v. Commissioner, T.C. Memo. 1991-451, affd. without published opinion 5 F.3d 536 (9th Cir. 1993). Respondent filed the above-referenced motion in the instant case with respect to the disallowance of deductions, investment tax credits, and related additions to tax in connection with petitioners' participation in the Encore Leasing Program (Encore). In their response, petitioners failed to provide the Court with an adequate basis upon which they could distinguish themselves from the previously decided cases and were ordered to either sign a stipulated decision in the instant case or appear before the Court for a hearing on the matter. This case was heard at a motions session held on March 27, 1995, at Houston, Texas, and was taken under advisement. Petitioners resided in Kountz, Texas, at the time the petition was filed. Mr. Brooke (petitioner) was employed as a loan officer at a savings and loan when he invested in Encore. The instant case arises out of petitioners' participation in Encore. Encore was in the business of leasing master recordings of previously released pop and gospel albums.1 Trials were 1For a detailed discussion of the facts and the applicable law with respect to participation in the Encore Leasing Program, see Booker v. Commissioner, T.C. Memo. 1996-261; Wolf v. Commissioner, T.C. Memo. 1991-212, affd. 4 F.3d 709 (9th Cir. 1993); Feldman v. Commissioner, T.C. Memo. 1991-353, affd. (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011