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Snyder filed joint Federal income tax returns with his former
wife, Joni Evans Snyder. She is not a party to these cases. On
their joint 1982 Federal income tax return, Ronald and Rochelle
Busch reported gross income from wages, interest, dividends, and
State and local tax refunds in excess of $370,000. Consequently,
in the absence of significant deductions or credits, petitioners
in these consolidated cases were subject to payment of Federal
income taxes in substantial amounts.
In 1981, Snyder acquired a 4.479638-percent limited
partnership interest in SAB Recovery for $50,000. This amount is
the gross amount Snyder invested, unreduced by any sales
commission rebates or his share of any advance royalty
distributed to him. On his 1981 return, Snyder claimed an
operating loss in the amount of $39,698 and investment tax and
business energy credits totaling $82,536,7 both flowing from his
interest in SAB Recovery. In 1982, Snyder acquired a 9-percent
interest in SAB Reclamation, also for $50,000. On his 1982
return, he claimed an operating loss in the amount of $40,100 and
investment tax and business energy credits totaling $83,712, both
as a result of his investment in SAB Reclamation. Snyder also
claimed an operating loss in the amount of $2,291 with respect to
SAB Recovery in 1982. Respondent disallowed Snyder's claimed
7 The regular investment tax credit claimed by Snyder totaled
$41,342, but only $41,268 of that amount was attributable to SAB
Recovery.
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