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investments that year and changed its function to leasing
Sentinel EPE recyclers. Partners were given the option of
withdrawing their capital accounts or continuing with the
partnership. In December 1981, SAB Associates invested $569,600
in SAB Resource Recovery Associates and $975,000 in SAB Leasing
Associates. Investment tax credits and business energy credits
with respect to petitioners' shares of these investments are not
reflected in the records in these cases, presumably because the
investments were made in 1981. Only the operating losses in 1982
are documented in the record in these cases.
In 1982, Spears acquired a 2.538461-percent interest in SAB
Recycling for $25,000.11 On their 1982 return, he and his wife
Joan claimed an operating loss in the amount of $19,870 and
investment tax and business energy credits totaling $41,32012
with respect to his interest in SAB Recycling. They also claimed
an operating loss in the amount of $1,145 with respect to their
interest in SAB Associates. Respondent disallowed all of their
11 The gross amount Spears invested is $25,000, unreduced by
any sales commission rebate or his share of any advance royalty
distributed to him.
12 The regular investment tax credit claimed by Spears and his
wife totaled $54,863, but only $20,660 of that amount was
attributable to SAB Recycling.
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