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On its 1983 and 1984 returns, the Barrister partnership
claimed ordinary losses in the amounts of $848,599 and
$1,059,623, respectively, and qualified investment credit
property in the amounts of $18,809,500 and $6,110,000,
respectively. The Barrister partnership attached disclosure
statements to its 1983 and 1984 returns which state that its sole
business was "the printing and sale of 49 different literary
works and microcomputer disks aimed at a general public market,
using leased films, plates and disks to produce said products."
On their 1983 return, Catherine and Gus claimed an ordinary
loss in the amount of $10,477 and an investment tax credit in the
amount of $18,578 with respect to their $25,000 investment.
Since the alternative minimum tax nullified the benefit of part
of the investment tax credit for 1983, Catherine and Gus filed
amended returns for 1980 and 1982 to carry back portions of the
1983 credit to offset their previously reported tax liability for
the 1980 and 1982 taxable years.2 They also claimed an ordinary
loss in the amount of $13,083 and an investment tax credit in the
amount of $6,035 for their 1984 taxable year with respect to
their investment in the Barrister partnership.
2 The parties stipulated that the amounts of the
investment tax credit carrybacks for 1980 and 1982 are $9,571 and
$1,190, respectively, which differ from the amounts claimed on
the 1980 and 1982 amended returns ($4,577 and $6,184). Since we
have found no explanation in the record for these differences,
and the parties have not made any reservations to their
stipulations, we accept the amounts stipulated as correct.
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