- 43 - 1383, 1386 (9th Cir. 1988), affg. Dister v. Commissioner, T.C. Memo. 1987-217; Sacks v. Commissioner, supra. According to the offering memoranda, for each $50,000 investor, the projected first-year tax benefits were investment tax credits in excess of $82,500, plus deductions in excess of $40,000.11 In the case of SAB Recovery, which closed December 21, 1981, these tax benefits accrued in less than 2 weeks. As a result of his $25,00012 investment in SAB Reclamation in 1982, Busch claimed an operating loss in the amount of $20,050 and investment tax and business energy credits in the amount of $41,856. For his $50,000 investment in SAB Recovery in 1981, Snyder claimed an operating loss in the amount of $39,698 and investment tax and business energy credits totaling $82,536. In 1982 Snyder claimed an operating loss in the amount of $40,100 and investment tax and business energy credits totaling $83,712, both flowing from his $50,000 investment in SAB Reclamation that year. The direct reductions claimed on petitioners' Federal income tax returns, from the investment tax credits alone, equaled 167 11 The projected tax benefits for the Partnerships in the first year of the investment, for each $50,000 investor, were as follows: Investment tax credits of $82,639, plus deductions of $40,003 for SAB Recovery in 1981, and investment tax credits of $83,712 and deductions of $40,234 for SAB Reclamation in 1982. 12 The amounts invested by petitioners as set forth above are the gross amounts invested, unreduced by any rebated commissions or advance royalty payments.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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