Robert W. and Vivian Toan - Page 4




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          $13,100,000.  The equipment’s fair market value was actually no             
          greater than $381,000, and its claimed tax basis exceeded its               
          fair market value by at least 3,483 percent.                                
               Petitioners claimed on their 1982 Federal income tax return            
          that their share of the equipment’s tax basis was $61,647                   
          (.470589 percent times $13,100,000) and that this basis qualified           
          for the investment tax credit.  Petitioners were unable to use in           
          1982 all of their claimed investment tax credit relating to the             
          equipment, and they carried back and applied $894 of the credit             
          to 1979, $10,331 of the credit to 1980, and $2,126 of the credit            
          to 1981.                                                                    
               Respondent audited Catamount and determined that Catamount             
          was not entitled to an investment tax credit for 1982 because it            
          had no basis in qualified investment tax credit property.                   
          Respondent timely issued a notice of final partnership                      
          administrative adjustment (FPAA) to Catamount’s tax matters                 
          partner (TMP) reflecting this adjustment, and the TMP timely                
          petitioned this Court to readjust the adjustments reflected in              
          the FPAA.  See Catamount Associates v. Commissioner, docket No.             
          12298-90.  On March 4, 1994, the Court entered a decision in the            
          Catamount Associates case reflecting Catamount's concession that            
          it had no basis in qualified investment tax credit property.                
          That decision became final on June 2, 1994.                                 







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