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Petitioners are the sole stockholders of Thompson Electric.
Petitioner has no experience in the music recording industry.
During 1984, petitioner was a partner in the Alamo
partnerships. The Alamo partnerships were formed by Neil Orsi
(Orsi), who served as the partnerships' managing general partner.
During 1984, petitioners invested $10,000 in Alamo East
Enterprises 1984. On their 1984 Federal income tax return,
petitioners claimed net loss deductions in the total amount of
$23,858 and investment tax credits in the amount of $17,962 with
respect to their participation in the Alamo partnerships.
Petitioners applied a portion of the investment tax credits to
offset their 1984 taxes (except for their alternative minimum
tax) and carried back $11,744 of the investment tax credits to
offset their 1981 tax liability.
On May 8, 1995, this Court granted respondent's motions to
dismiss for lack of prosecution petitions filed by Orsi, as tax
matters partner, on behalf of the Alamo partnerships. The Court
further decided that the adjustments for the 1984 taxable year
were correct as determined and set forth in the Notices of Final
Partnership Administrative Adjustment (FPAA). Respondent's
determinations in the FPAA's involved only the activities
surrounding the leasing of master recordings with respect to both
partnerships.
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