- 5 - spouse, Roberta, was not employed outside the home. On their 1981 Federal income tax return, petitioners Stone reported gross income from wages, interest, and dividends in excess of $250,000. Consequently, in the absence of significant deductions or credits, they were subject to payment of Federal income taxes in substantial amounts for taxable year 1981. Petitioner Joseph Cote (Cote) was a corporate bond trader for Merrill Lynch, Pierce, Fenner & Smith, Inc. (Merrill Lynch), during 1981. His wife, Mary, was not employed outside the home. On their 1981 Federal income tax return, petitioners Cote reported gross income from wages, interest, and dividends in excess of $320,000. Consequently, in the absence of significant deductions or credits, they were subject to payment of Federal income taxes in substantial amounts for taxable year 1981. Stone is a limited partner in Northeast Resource Recovery Associates (Northeast) and Cote is a limited partner in Hyannis Recycling Associates (Hyannis). For convenience, we refer to these two partnerships collectively as the Partnerships. Petitioners have stipulated that the transactions involving the Sentinel EPE recyclers leased by the Partnerships are substantially identical to those in the Clearwater Group limited partnership (Clearwater), the partnership considered in Provizer v. Commissioner, T.C. Memo. 1992-177. In addition, petitioners have stipulated substantially the same facts concerning the underlying transactions as we found in the Provizer case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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