Stuart A. and Harriet J. Gollin, et al. - Page 55

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          & 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 energy                







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