Jeffrey I. and Roberta H. Stone - Page 9

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          passthrough from Northeast, on their 1981 Federal income tax                
          return the Stones deducted an operating loss in the amount of               
          $20,340 and claimed investment tax and business energy credits              
          totaling $42,406.  The underlying deficiency in the Stone case              
          results from respondent's disallowance of the Stones' claimed               
          operating losses and credits related to Northeast.                          
               Also during 1981, Cote acquired a 6.187-percent interest in            
          Hyannis for his investment of $50,000.5  As a result of the                 
          passthrough from Hyannis, on their 1981 Federal income tax return           
          the Cotes deducted an operating loss in the amount of $40,646 and           
          claimed investment tax and business energy credits totaling                 
          $74,611.  An additional $4,583 of the 1981 business energy credit           
          was carried back to 1980.  The Cotes' underlying deficiencies for           
          taxable years 1980 and 1981 result from respondent's disallowance           
          of their claimed operating losses and credits related to Hyannis.           
               Cote and Stone are both well educated and very successful              
          and sophisticated businessmen.  Stone holds a B.S. in electrical            
          engineering from Northeastern University and an M.B.A. from                 
          Babson College.  After college he worked for the Raytheon and               
          Hewlett-Packard companies, and in 1975 he started his own                   
          electronic components company, Stone Component Sales Corp.  Cote            

          5    The parties stipulated that Cote owned a 3.094-percent                 
          interest in Hyannis.  However, Cote's 1981 Form K-1, Partner's              
          Share of Income, Credits, Deductions, etc., attached to the                 
          Hyannis partnership return, indicates that he acquired a 6.187-             
          percent interest in Hyannis.  The reason for this discrepancy is            
          not explained in the record.                                                




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