- 12 - 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 taxablePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011