Estate of Ronald Busch, Deceased, Rochelle Busch, Executrix and Rochelle Busch, et al. - Page 18

                                       - 18 -                                         
          1981 and 1982 operating losses and credits related to his                   
          investments in SAB Recovery and SAB Reclamation.8                           
               During 1982, Busch acquired a 4.5-percent interest in SAB              
          Reclamation for $25,000.  This amount is the gross amount Busch             
          invested, unreduced by any sales commission rebate or his share             
          of any advance royalty distributed to him.  On their 1982 return,           
          he and his wife claimed an operating loss in the amount of                  
          $20,050 and investment tax and business energy credits totaling             
          $41,856 with respect to his investment in SAB Reclamation.  They            
          also claimed an operating loss in the amount of $1,145 with                 
          respect to a 2.239819-percent interest Busch owned in SAB                   
          Recovery.  Respondent disallowed all but $65.60 of their claimed            
          operating losses and all of their credits related to the                    
          investments in SAB Reclamation and SAB Recovery.                            
               Sometime in the late 1970's, Snyder hired Becker to be his             
          accounting and financial adviser.  During that time Snyder                  
          introduced Becker to Busch, who soon thereafter also became a               
          client of Becker's firm.  In 1981 Becker introduced the                     
          Partnership transactions to Snyder.  Becker believed that the               
          Partnership transactions would appeal to Snyder because Snyder              

          8    Snyder reported a total loss in 1982 from his partnership              
          interests in the amount of $124,012.  In an attached statement              
          itemizing those losses, Snyder reported a loss from SAB Recovery            
          in the amount of $2,291.  In the notice of deficiency, however,             
          respondent indicates that Snyder reported an operating loss of              
          $2,160 from SAB Recovery and disallowed that amount in full.  The           
          reason for this discrepancy is unclear from the record.                     





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

Last modified: May 25, 2011