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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 New
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