- 42 -
IT and BE Credits Deductions
Empire $84,813 $40,650
Plymouth 82,639 40,376
Foam 76,736 39,878
With respect to their combined indirect investments in Empire and
Plymouth, petitioners claimed the following total tax benefits on
their 1981 Federal income tax returns.20
Total Combined
Investment IT and BE Credits Loss
Sann $93,750 $156,900 $67,156
Addington 31,520 53,416 22,467
Cohn 6,250 8,156 4,503
With respect to their indirect investments in Foam, petitioners
claimed the following tax benefits on their 1982 Federal income
tax returns.
Investment IT and BE Credits Loss
Sann $50,000 $76,767 $35,272
Addington 25,000 35,094 17,637
Cohn 6,000 9,212 4,232
The total of investment tax and business energy credits
ostensibly generated by the Partnerships and available to
petitioners was more than 1 � times their cash investments.
Therefore, after adjustments of withholding, estimated tax, or
final payment, like the taxpayers in Provizer v. Commissioner,
T.C. Memo. 1992-177, "except for a few weeks at the beginning,
petitioners never had any money in the * * * [Partnership
transactions]." In view of the disproportionately large tax
benefits claimed on petitioners' Federal income tax returns,
20 As noted, Cohn invested in S&H Empire but not in Plymouth
Partners.
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