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INVESTORS 80,000 DuFresne
INVESTORS 120,000 Dixon
INVESTORS 120,000 Young
Taxable Year 1982
Program Petitioner(s)
ANSETH LEASING Young
CHARTER 120,000 DuFresne
CHARTER 120,000 Young
INVESTORS 80,000 DuFresne
INVESTORS 120,000 Young
Taxable Year 1983
Program Petitioner(s)
ANSETH LEASING Young
CHARTER 120,000 DuFresne
INVESTORS 80,000 DuFresne
1 Maurier Leasing, a subch. S leasing program, was
considered by the Court in Pike v. Commissioner, 78 T.C. 822
(1982).
The notice of deficiency issued to the Thompsons for the
taxable year 1981 states in pertinent part: "Based on
examination information from the 1978, 1979, and 1980 returns,
the investment interest is generated from the interest deduction
tax shelter. The purported payees cannot be identified from the
1981 income tax return filed by the taxpayers." Respondent has
not been able to identify specifically the Kersting programs that
the Thompsons participated in during 1981. However, the record
suggests that, in addition to the Kersting programs that the
Thompsons participated in during 1979 and 1980, the Thompsons
participated in the Anseth Leasing Program during 1981.
If the Thompson and Cravens cases had been removed from the
test case array, there would have been no reduction in coverage
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