- 20 -
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.
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011