- 15 -
with the plastics recycling industry. Moreover, the engineer and
Thornsjo’s colleague did not testify during the trial.
Thornsjo does not have any education or experience with the
plastics or plastics recycling industries. Moreover, Thornsjo
did not personally review the Hamilton offering memorandum prior
to investing in Hamilton. He did not employ a capable and
responsible person to investigate the value of the plastic
recyclers before investing. Instead, Thornsjo contends that he
relied upon Schluter’s, the Honeywell engineer’s, and his
colleague’s advice when he invested in Hamilton. Thornsjo also
contends that he invested in Hamilton because he considered
Hamilton a good investment for his retirement. In 1982, Thornsjo
paid $25,000 for his partnership interest in Hamilton.
As a result of his investment in Hamilton, on his 1982
Federal income tax return Thornsjo claimed a net operating loss
deduction of $19,578 and investment tax and business energy
credits totaling $38,500, which was limited to his 1982 income
tax liability (as reduced by the partnership loss) of $4,088.
The balance of the credits, $34,412, was carried back to 1979 and
1980 to generate tax refund claims of $17,937 and $16,475,
respectively. On his 1983 Federal income tax return, Thornsjo
claimed a net operating loss deduction of $963 as a result of his
investment in Hamilton.
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011