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Reclamation, on their 1982 return petitioners claimed an
operating loss in the amount of $8,0217 and investment tax and
business energy credits in the amount of $16,742. Respondent
disallowed the operating losses and credits related to SAB
Recovery and claimed by petitioners on their 1981 return. With
respect to petitioners' 1982 return, respondent disallowed $432
of the claimed $458 loss related to SAB Recovery; $2,475 of the
claimed $8,021 loss related to SAB Reclamation; and $5,166 of the
claimed $16,742 investment tax and business energy credits
related to SAB Reclamation.
7 The total operating loss claimed by petitioners on their
1982 return, from both SAB Reclamation and SAB Recovery, was
$8,479. ($8,021 + $458 = $8,479).
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