- 21 - claimed operating losses and credits related to their interests in SAB Recycling and SAB Associates. In 1982, Farrell acquired a 4.5-percent limited partnership interest in SAB Reclamation for $25,000.13 On their 1982 return, he and his wife Clotilde claimed an operating loss in the amount of $20,050 and investment tax and business energy credits totaling $41,856,14 both flowing from his interest in SAB Reclamation. The Farrells also claimed an operating loss in the amount of $1,906 with respect to SAB Associates.15 Respondent disallowed all but $386 of the Farrell's 1982 claimed operating losses and credits related to SAB Reclamation and SAB Associates.16 13 Farrell testified that he believed he had invested $20,000. His Form K-1, Partner's Share of Income, Credits, Deductions, etc., attached to SAB Reclamation's partnership return, indicates that he invested $25,000. We note that the $25,000 figure is the gross amount Farrell invested, unreduced by any rebated sales commission or his share of any advance royalty distributed to him. 14 The regular investment tax credit claimed by Farrell and his wife totaled $21,314, but only $20,928 of that amount was attributable to SAB Reclamation. 15 As noted, respondent and Farrell stipulated that for taxable year 1982, he and his wife are entitled to deduct $381 with respect to their interest in SAB Associates. 16 Respondent explained in the notice of deficiency that (continued...)Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011