- 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.
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