Estate of Ronald Busch, Deceased, Rochelle Busch, Executrix and Rochelle Busch, et al. - Page 17

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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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