- 27 - 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.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011