John Sann and Marianne Sann, et al. - Page 23

                                       - 23 -                                         
          and a law degree from Yale Law School in 1961.  After service in            
          the Army, Addington moved to New York City and was employed in              
          the trust department of the Morgan Guaranty Trust Company.                  
          Approximately 4 or 5 years later, in 1967, he joined the law firm           
          of Breed, Abbott & Morgan and practiced in their trusts and                 
          estates department.  In 1973 he joined the law firm of Sann &               
          Howe, and he became a partner in that firm the following year.              
          Addington specializes in estate planning and administration.                
               In 1981, Addington acquired an indirect, limited partnership           
          interest in Empire with a $25,000 investment in S&H Empire, and             
          an indirect limited partnership interest in Plymouth with a                 
          $6,520 investment in Plymouth Partners.  In 1982, he acquired an            
          indirect, limited partnership interest in Foam with a $25,000               
          investment in Jabrilach Recycling.                                          
               As a result of his indirect investments in Empire and                  
          Plymouth, on his 1981 Federal income tax return Addington claimed           
          operating losses in the respective amounts of $18,013 and $4,454,           
          and investment tax and business energy credits totaling $53,416.9           
          Addington also claimed operating losses from Empire and Plymouth            
          on his 1982 return in the respective amounts of $406 and $141.              
          As a result of his indirect investment in Foam, on his 1982                 
          return Addington claimed an operating loss in the amount of                 


          9    The notice of deficiency in docket No. 21519-88 indicates              
          that of the $53,416 in credits, $43,080 derived from Empire                 
          ($21,876 in investment tax credits and $21,204 in business energy           
          credits) and $10,336 derived from Plymouth ($5,158 in investment            
          tax and business energy credits each).                                      



Page:  Previous  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  Next

Last modified: May 25, 2011