- 6 - Southampton investment was that "If they would do everything that they said in the booklet, it looked okay to him." Based on his discussions with Cunningham and Parnell, and on his own research of the music industry, petitioner decided to invest in Southampton and signed a master recording lease agreement on December 22, 1982. Petitioner was aware of the tax benefits expected from the investment. The availability of those benefits for the 1982 taxable year had an impact on petitioner's decision to sign the lease agreement prior to the end of the year. Pursuant to the agreement, petitioner was to pay Southampton a total of $10,5003 for a one-fourth leasehold interest in a master recording featuring Ray Pillow, a country- western singer. The lease was for a term of 5 years and 10 months. Petitioner had not listened to or received a copy of the Ray Pillow master recording prior to investing in Southampton. Petitioner's master recording was to be distributed as a phonograph album by Indigo Music Co. (Indigo), a distributor recommended to petitioner by Southampton. Petitioner did not meet or negotiate with anyone from Indigo prior to investing in Southampton. Pursuant to his agreements with Indigo and 3 Petitioner paid $8,400 on or about the date the lease was signed and reported that amount as rental expense on his 1982 tax return. The remaining $2,100 was paid approximately 1 year thereafter and reported as rental expense on petitioner's 1983 return.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011