- 12 - Friedman used $9,290 on his 1981 return.2 Respondent disallowed Friedman's claimed operating loss and investment credit flowing from Clearwater.3 Friedman was told about the Plastics Recycling transactions by several partners at Shea & Gould. Approximately eight partners contemplated investing in a Plastics Recycling transaction. Friedman understood that Stuart Hirshfield (Hirshfield), a bankruptcy specialist at Shea & Gould, previously had done business with Winer and thought well of him. Hirshfield and two other partners, Dan Carroll (Carroll) and Lonn Trost (Trost), each made inquiries about some aspects of the Plastics Recycling transactions. Friedman also understood that Trost and Hirshfield visited PI at least once and viewed some Sentinel EPE recyclers. Alan Parker (Parker), a tax partner, reviewed the tax 2 Friedman's basis in the Clearwater Sentinel EPE recyclers was $107,918. He had a basis in other property qualifying for the investment tax credit in the amount of $3,211. Friedman's tentative investment tax and business energy credits flowing from Clearwater each totaled $10,792. However, Friedman's business energy credit was subject to a limitation in the amount of zero, and his regular investment credit was subject to a limitation in the amount of $9,611. Of the total investment credit claimed in 1981 by Friedman, $9,290 was from Clearwater and $321 was from other qualifying property. The record in docket No. 24753-89 does not disclose whether Friedman carried forward or back his unused credits. 3 Respondent allowed $321 in investment tax credits related to other property not at issue herein.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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