- 55 -- 55 - & G Corp. and his representation of Burstein, PI, and Grant, who was the sole shareholder of ECI Corp. A careful consideration of the materials in the offering memoranda in these cases, especially the discussions of high writeoffs and risk of audit, should have alerted a prudent and reasonable investor to the questionable nature of the promised deductions and credits. See Collins v. Commissioner, 857 F.2d 1383, 1386 (9th Cir. 1988), affg. Dister v. Commissioner, T.C. Memo. 1987-217; Sacks v. Commissioner, T.C. Memo. 1994-217. In each of these consolidated cases the projected tax benefits in the respective offering memoranda exceeded petitioners' respective investments. According to the offering memoranda, for each $50,000 investor, the projected first-year tax benefits were investment tax credits in excess of $82,600 plus deductions in excess of $40,000. Specifically, the projected investment tax credits and deductions for the Partnerships in the first year of the investment for each $50,000 investor were as follows: IT + BE Credits Deductions SAB Recovery $82,639 $40,003 SAB Recycling 82,639 40,037 SAB Reclamation 83,712 40,234 As a result of Gollin's gross $12,500 investment in SAB Reclamation, he and his wife Harriet claimed an operating loss in the amount of $10,025 and investment tax and business energyPage: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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