- 3 - the investment tax credit and $424,106 of property qualifying for the business energy credit, partially resulting in a $43,722 claimed regular investment tax credit and resulting in a $42,411 claimed business energy investment credit with respect to RRA. Petitioner invested $50,000 in RRA. By letter dated February 19, 1988, respondent proposed to disallow the deductions from RRA and Greenfield and the credits from RRA. Petitioner was represented by the law firm of Kirkland & Ellis with respect to the Greenfield issues. By letter dated March 30, 1988, Kirkland & Ellis asked that the RRA issues be deferred until the Greenfield issues are resolved. On September 6, 1990, respondent’s Appeals Office executed a closing agreement with respect to the Greenfield issues. That agreement was signed by Steven Kamerman (Mr. Kamerman) on behalf of petitioner. With regard to RRA, on August 2, 1990, Mr. Kamerman and petitioner executed a closing agreement. That agreement was signed by respondent’s Appeals Office on September 6, 1990. The agreement provided, inter alia: (1) The taxpayer [petitioner] has claimed income, deductions, and/or credits on his tax returns for the taxable years 1981 and 1982 relating to the Resource Reclamation Assoc. tax shelter (hereafter the TAX SHELTER) which are in dispute between the taxpayer and the Commissioner of Internal Revenue (hereafter the IRS). (2) Items of income, deductions, and/or credits relating to the TAX SHELTER are in issue in a case pending before the United States Tax Court Harold M. Provizer and Joan Provizer v. Commissioner, Docket No. 27141-86 (hereafter the CONTROLLING CASE).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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