- 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