- 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 Next
Last modified: May 25, 2011