Michael A. Lacher and Judith W. Lacher - Page 6




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          standard settlement offer was made available to taxpayers in                  
          nondocketed Plastics Recycling cases.  See Baratelli v.                       
          Commissioner, T.C. Memo. 1994-484.  The standard settlement offer             
          allowed a deduction for 50 percent of the amount of the                       
          taxpayer’s cash investment, Government concessions of the                     
          negligence addition to tax, and the taxpayer’s concession of the              
          valuation overstatement addition to tax and increased interest.               
          The standard settlement offer expired in 1989 following the trial             
          of Provizer v. Commissioner, supra.  See Baratelli v.                         
          Commissioner, supra n.3.                                                      
          Petitioner and His Involvement in SAB                                         
               Petitioner is an experienced attorney who has litigated                  
          cases for more than 35 years.  Petitioner is well aware that                  
          cases can be resolved through settlement at various stages of                 
          litigation.                                                                   
               In 1981, petitioner acquired a limited partnership interest              
          in SAB.  As a result of petitioners’ investment in SAB, they                  
          claimed a net operating loss deduction of $39,697 and investment              
          tax credits and business energy credits totaling $82,558 on their             
          1981 Federal income tax return, which was limited to petitioners’             
          1981 income tax liability (as reduced by the partnership loss) of             
          $58,232.  The balance of the credits, $24,326, was carried back               
          to the years 1978 and 1979 to generate tax refund claims of                   
          $11,489 and $12,837, respectively.                                            






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