Oreland A. and Lucille S. Thornsjo - Page 9




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          losses that Hamilton had reported on its 1982, 1983, and 1984               
          Federal income tax returns and determined that Hamilton did not             
          incur “a loss in a trade or business or in an activity entered              
          into for profit or with respect to property held for the                    
          production of income.”  In the FPAA’s, respondent also determined           
          that for purposes of the investment tax and business energy                 
          credits Hamilton’s basis in the recycling equipment was zero,               
          rather than $7 million.                                                     
               Subsequently, a petition was filed by Hamilton’s TMP.  On              
          February 23, 1994, the Court entered a decision in Hamilton                 
          Recycling Associates v. Commissioner, docket No. 9990-89.  This             
          decision reflects a full concession by Hamilton of all items of             
          income, loss, and the underlying equipment valuation used for tax           
          credit purposes.                                                            
          D.  Richard C. Schluter                                                     
               Richard C. Schluter (Schluter) is a certified public account           
          (C.P.A.), who practiced from 1964 until his retirement in 1991.             
          Much of his practice related to the construction industry, and              
          many of his clients needed bonding for contracts.  Also, he                 
          represented individuals, and about half his practice was tax-               
          related.                                                                    
               In the late 1960’s, Schluter became involved with various              
          aspects of tax shelter promotions.  From 1971 until his                     
          retirement, Schluter compiled public offering securities audits,            
          mostly for tax shelter promotions.  Schluter also reviewed tax              




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