- 7 - Southampton, petitioner was to receive royalty payments from Indigo on album sales, and in turn, petitioner was to make additional rental payments to Southampton based on a percentage of net profits earned. There is no evidence in the record that petitioner has ever received royalty payments from Indigo or that any additional rental payments have been made to Southampton.4 Pursuant to the lease agreement, Southampton agreed to pass to petitioner his one-fourth share of any investment tax credit generated by the Ray Pillow master recording. On his 1982 tax return, petitioner reported a tentative regular investment credit from his Southampton investment of $21,250. This amount was determined based on a value for the Ray Pillow master recording reported to petitioner by Southampton of $850,000.5 Petitioner never obtained an independent appraisal of the Ray Pillow master recording but relied solely on the value reported to him by Southampton.6 Of the total investment tax credit of 4 On his 1984 tax return, however, petitioner reported $15 in "Other Income" from his Southampton investment. 5 Petitioner's tentative regular investment tax credit was determined by multiplying the regular investment tax credit percentage (10 percent) by petitioner's one-fourth share of the total value of the master recording reported by Southampton (10 percent x ($850,000 x �) = $21,250). 6 Petitioner introduced into evidence two documents that he received from Southampton purporting to be appraisals of the Ray Pillow master recording. Petitioner's reliance on these (continued...)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