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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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