James D. Barber and Betty L. Barber - Page 27




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          investment tax credit and energy tax credit in the aggregate                
          amount of $17,511.  Petitioners also claimed a loss in the amount           
          of $11,852 for their distributive share of the partnership’s                
          reported loss for 1982.  The investment credits and the                     
          partnership loss served to reduce petitioners’ liability for                
          Federal income tax as reported on their 1982 return by $23,240.11           
               2.  Other Partnerships                                                 
               Petitioners reported losses from partnerships other than               
          Whitman on their income tax returns for 1982 and 1983, as                   
          follows:                                                                    
                    Partnership            1982         1983                          
                    University Associates  $589         $554                          
                    Winer Development       255          —                            
                    Columbian Oil & Gas     –--         3,441                         
                    Enterprise Energy       –--         3,074                         
               Petitioners did not report any income or gain in respect of            
          any partnership on either their 1982 or 1983 tax return.                    
          J.   The Partnership-Level Proceeding                                       
               Whitman is a so-called TEFRA partnership subject to the                
          unified partnership audit and litigation procedures set forth in            
          sections 6221 through 6233.  See Tax Equity and Fiscal                      


               11  Petitioners also claimed a loss on their 1983 return in            
          the amount of $594 for their distributive share of Whitman’s                
          reported loss for that year.  The partnership loss served to                
          reduce petitioners’ tax liability for 1983 by $193.                         
               The record does not reveal whether petitioners claimed                 
          losses from Whitman on their returns for years after 1983;                  
          however, the record does establish that petitioner never made a             
          profit in any year from his investment in Whitman.                          





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