- 28 - and $39,162, respectively. For his $12,500 investment in Clearwater, Friedman claimed an operating loss in the amount of $10,002, and investment tax and business energy credits in the amount of $9,29010 on his 1981 return. As a result of Alter's $12,500 investment in Poly Reclamation, on their 1981 return he and his wife Deborah claimed an operating loss in the amount of $9,976 and investment tax and business energy credits totaling $21,584. The investment tax and business energy credits generated by the Partnerships and available to petitioners equaled 173 percent of their cash investments. Therefore, after adjustments of withholding, estimated tax, or final payment, and possible carryback or carryover in Friedman's case, like the taxpayers in Provizer v. Commissioner, T.C. Memo. 1992-177, "except for a few weeks at the beginning, petitioners never had any money in the * * * [Partnership transactions]." In view of the disproportionately large tax benefits claimed on petitioners' Federal income tax returns, relative to the dollar amounts invested, further investigation of the Partnership transactions clearly was required. A careful consideration of the materials 10 As noted, the total amount of investment tax and business energy credits flowing from Clearwater to Friedman in 1981-- $21,584--was subject to limitation.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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