- 3 - otherwise stated, section references are to the Internal Revenue Code in effect for the year in issue. FINDINGS OF FACT The stipulated facts and exhibits submitted therewith are incorporated herein by this reference. When he petitioned the Court, petitioner resided in Salisbury, Maryland. Petitioner filed a 1982 Form 1040, U.S. Individual Income Tax Return. The income that he reported on that return included $11,945 of wages, salaries, tips, etc.; $23,489 in dividends; and $325,491 of business income. Petitioner purchased a 4.95-percent limited partnership interest in Elite in December 1982. Elite was formed on December 15, 1982, with 18 partners. Its principal business activity was leasing energy conservation equipment, with a view to making use of the energy credit under section 48(l). On or about October 17, 1983, Elite filed its 1982 Form 1065, U.S. Partnership Return of Income. On this return, Elite reported that it had purchased $1,365,141 in energy equipment in 1982, and claimed depreciation and energy credits with respect thereto. Petitioner's 1982 Form 1040 reported his $2,281 share of Elite's depreciation, and it reported his $9,825 share of Elite's energy credit. In December 1986, petitioner moved abroad to lecture at Massey University in New Zealand. During 1987, while in NewPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011