- 48 - supra. Indeed, Grelsamer testified that when he reviewed the SAB Reclamation offering memorandum he thought that the "mathematics looked terribly good, maybe too good." In each case, the projected tax benefits in the 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 $82,500 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: $82,639 and $40,376, respectively, for Plymouth in 1981, and $83,712 and $40,234, respectively, for SAB Reclamation in 1982. For Grelsamer's gross $25,000 investment, the Grelsamers claimed an operating loss in the amount of $20,050 and investment tax and business energy credits in the amount of $41,856 for taxable year 1982. As a result of his $50,000 investment, Morgan claimed a $40,554 operating loss and $82,526 in investment tax and business energy credits for taxable year 1981. The direct reductions in petitioners' Federal income tax, from the investment tax credits alone, ranged from 165 percent to 167 percent of their cash investments, without taking into consideration any rebated commissions or advance royalty payments. Therefore, after adjustments of withholding, estimatedPage: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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