- 9 - 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.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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