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investment this tax credit relates. When petitioner reviewed the
1979 Form 1040, the deductions related to the tax shelters had no
meaning to her, and she did not understand the financial
consequences of the tax shelter investments.
For the taxable year 1980, Gerald claimed a deduction of
$52,110 attributable to the investment in Power Control.
Respondent disallowed the aforementioned deductions and
investment tax credits attributable to the tax shelters, and the
Jacobys filed a petition in this Court.
In 1992, Gerald and respondent entered into a stipulation of
settlement. For the taxable year 1978, Gerald conceded that he
was not entitled to any loss attributable to Hawk Mining, Mason
Coal, or T.A.B. Production. Gerald also conceded that he was not
entitled to the investment tax credit claimed for 1978.
Respondent conceded that Gerald was entitled to a $40,000 loss
resulting from Masada Press, Ltd., that amount being equal to his
cash investment. For the taxable year 1979, Gerald conceded that
he was not entitled to any loss attributable to Hawk Mining, or
Masada Press, Ltd. Gerald also conceded that he was not entitled
to the investment tax credit claimed for 1979. Respondent
conceded that Gerald was entitled to a $35,617 loss resulting
from Power Control. For the taxable year 1980, Gerald conceded
that he was not entitled to any loss attributable to Power
Control. Gerald conceded that the deficiencies for the taxable
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