John Sann and Marianne Sann, et al. - Page 20

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          indirect, limited partnership interest in Foam with a $50,000               
          investment in Jabrilach Recycling.                                          
               As a result of Sann's indirect investments in Empire and               
          Plymouth, on their 1981 Federal income tax return Sann and his              
          wife Marianne claimed operating losses in the respective amounts            
          of $31,520 and $35,636, and investment tax and business energy              
          credits totaling $156,900.7  The Sanns also claimed operating               
          losses from Empire and Plymouth on their 1982 return in the                 
          respective amounts of $710 and $1,132.  As a result of his                  
          indirect investment in Foam, on their 1982 return the Sanns                 
          claimed an operating loss in the amount of $35,272 and investment           
          tax and business energy credits totaling $76,767.8  Respondent              
          disallowed the Sanns' claimed operating losses and credits                  
          related to Empire, Plymouth, and Foam in full, except for the               
          operating losses from Empire and Plymouth claimed on their 1982             
          return.  In addition, with respect to Empire, respondent                    
          determined a distributive share of income in the amount of $4,375           
          for 1981.                                                                   




          7    The Sanns claimed a total of $158,128 in investment credits            
          on their 1981 return.  The notice of deficiency indicates that              
          $74,210 of the credits derived from Empire and that $82,690 of              
          the credits derived from Plymouth.  The record in docket No.                
          21518-88 does not indicate the source of the additional $1,228 in           
          credits claimed by the Sanns.                                               
          8    The total investment credit claimed by the Sanns on their              
          1982 return was $101,502.                                                   




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