- 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 NextLast modified: May 25, 2011