Philippe and Nadine Grelsamer - Page 48

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          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, estimated           






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