- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011