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