- 6 - deciding to invest in Whitman he “felt confident of * * * [Clothier’s] ability and expertise” because in “all of the * * * [investments] that I’ve been involved with Kirk [Clothier], he has invested in the same ones”. Petitioner also explained that the Whitman Recycling transaction “was the second involvement I had with Kirk Clothier.” Petitioner was introduced to the Whitman investment by Clothier. Clothier explained to petitioner that investing in Whitman could serve three purposes: To make money, to shelter taxes, and to help the environment. Petitioners paid $25,000 for a 2.75-percent limited partnership interest in Whitman. Petitioners did not personally review Whitman’s offering memorandum or investigate Whitman before becoming participants in the partnership. Nor did petitioners have any education or work experience in the plastics materials or the plastics recycling industry. As a result of their payment of $25,000 for their interest in Whitman, petitioners claimed on their 1982 Federal income tax return a net operating loss deduction of $19,635. They also claimed investment credits totaling $38,763, which was limited to their 1982 income tax liability (as reduced by the partnership loss) of $24,815. Of the $13,948 balance of the unused credits, $8,007 was carried back to 1979, generating a tax refund claim ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011