- 9 - 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 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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