- 15 -
credits of $21,176 to 1979, $18,479 to 1980, and $6,332 to 1981.
These credits resulted from their investment in Southeast. They
did not claim any losses with respect to Southeast on any of
these returns.
From 1979 through 1980, Wilson's average adjusted gross
income was $82,444. In 1982, his adjusted gross income increased
substantially to $231,282 due to a gain realized on the
disposition of a capital asset. On his 1982 return, he claimed
investment tax credits of $43,042 and carried back credits of
$13,054 to 1979 and $881 to 1980. The credits resulted from his
investment in Southeast. Wilson did not claim any losses with
respect to Southeast on any of these returns.
On its 1983 return, G&W claimed a loss of $20,452 related to
Southeast. G&W also carried back investment tax credits of
$4,472 to 1980 and $10,514 to 1981. These credits resulted from
G&W's investment in Southeast.
On their 1982 return, the Hogards claimed a loss of $40,884
and investment tax credits of $81,200, which items related to
their investment in Esplanade. They used $1,600 of the credits
in 1982 and carried back investment tax credits of $22,580 to
1979, $28,358 to 1980, and $28,662 to 1981.
With respect to each petitioner, in the applicable notice of
deficiency, respondent disallowed all items of income, loss,
deductions, and credits attributable to Southeast or Esplanade.
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011