Myron Barlow and Arlene Barlow - Page 23




                                        - 23 -                                         
          income tax return for 1982, the initial year of investment in                
          Dickinson, exceeded their $50,000 investment in the partnership.             
          Thus, on their 1982 return, petitioners claimed a regular                    
          investment credit and an energy investment credit in the                     
          aggregate amount of $77,001 in respect of the recyclers.                     
          Petitioners also claimed a loss in the amount of $39,155 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 $96,583.                                             
               Petitioners also claimed losses on their Federal income tax             
          returns for 1983 through 1985 for their distributive share of                
          Dickinson’s reported losses for those years as follows:                      
                         Year        Loss Claimed                                      
                         1983          $1,961                                          
                         1984             866                                          
                         1985           1,014                                          
               Petitioner never made a profit in any year from his                     
          investment in Dickinson.                                                     
          I.  The Partnership-level Proceeding                                         
               Dickinson was 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                       
          Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),             
          96 Stat. 648.  On May 15, 1989, respondent mailed a Notice of                
          Final Partnership Administrative Adjustment (FPAA) to Sam Winer,             





Page:  Previous  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  Next

Last modified: May 25, 2011