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$21,250, petitioner used $2,776.45 of the credit in 1982,
carried back unused credit in the amounts of $1,476, $3,402, and
$3,532 to 1979, 1980, and 1981, respectively, and carried
forward additional unused credit in the amounts of $3,693 and
$3,191.28 to 1983 and 1984, respectively. Petitioner had
$3,179.27 of unused investment tax credit to carry over into
later years. Additionally, on his 1983 tax return petitioner
deducted $2,750 in distribution costs relating to the
Southampton investment.
Petitioner's 1982 tax return was prepared by an accounting
firm, Chaness and Simon, and signed by a representative of that
firm on April 10, 1983. Petitioner provided the accounting firm
with the Southampton promotional booklet and an investment tax
credit election statement that he had received from Southampton
for use in preparing his 1982 return. Petitioner presumably
provided the same documents to Ramona Henderson, a C.P.A. who
petitioner claims prepared his 1983 tax return after petitioner
provided "receipts and information on all investments to her and
6(...continued)
documents as independent appraisals or as indications of his
expected economic benefit from the investment is misplaced as the
appraisals were commissioned by and addressed to Southampton and
were furnished to petitioner several months after petitioner made
his investment in Southampton and after his 1982 tax return was
filed.
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