- 3 -
Commissioner, T.C. Memo. 1990-640, affd. 1 F.3d 954 (9th Cir.
1993), control as to the income tax deficiencies. In the
aforementioned case it was decided that the taxpayer's energy
device had a fair market value not in excess of $1,000 (the
alleged purchase price was $80,000) and that the taxpayer was not
entitled to deductions and credits because his object was "solely
to gain a significant tax advantage and not to earn an economic
profit." Petitioner has conceded the income tax deficiencies in
this case, which are based on a disallowance of $9,100 loss from
Evergreen Partnership I (Evergreen) and investment tax credit
carrybacks and an investment tax credit of $4,176, $5,373,
$5,335, $973 for 1980, 1981, 1982, and 1983, respectively.
Additionally, respondent conceded that petitioner is not liable
for additions to tax under section 6659 for the taxable years
1980, 1981, 1982, or 1983.
FINDINGS OF FACT2
Petitioner resided in Veradale, Washington, at the time his
petition was filed in this case. After high school, petitioner
served 4 years in the U.S. Marine Corps until September of 1955,
when he began college. His major was in physical education.
Petitioner obtained a degree in 1959 and a master’s degree in
1961. From 1961 through the time of trial, petitioner taught
2 The parties' stipulation of facts, along with stipulated
documents, are incorporated by this reference.
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