- 24 - transaction. For the reasons already expressed herein, petitioner's motivation for investment in the energy device was to obtain the tax benefits, and his actions do not support his claim that he intended or expected to earn profits upon retirement or otherwise. Accordingly, we hold that petitioner is liable for the increased interest in each tax year. To reflect the foregoing and due to concessions, Decision will be entered under Rule 155.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Last modified: May 25, 2011