Jeffrey H. Weitzman - Page 10




                                       - 10 -                                         
          personally visited the Sentinel facility and had spoken with the            
          president of PI.  Jacobson told petitioner that it was a viable             
          investment.  Petitioner then purchased a $12,500 partnership                
          interest in Foam.                                                           
               On his 1982 Federal income tax return, petitioner claimed a            
          loss of $10,101 as his distributive share of the partnership’s              
          reported loss for 1982.  He also claimed a regular investment               
          credit and an energy investment credit in the aggregate amount of           
          $16,669.  Thus, the tax benefits petitioner claimed for his                 
          initial year of investment in the Partnership exceeded his                  
          $12,500 investment.  In 1986 petitioner filed an amended Federal            
          income tax return for 1982.  On the amended return petitioner               
          deducted his $12,500 investment in Foam and reversed the credits            
          and net loss from the Partnership he claimed on his original 1982           
          return.                                                                     
               Foam was a so-called TEFRA partnership subject to the                  
          unified partnership audit and litigation procedures set forth in            
          sections 6221 through 6233.  See Tax Equity and Fiscal                      
          Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),            
          96 Stat. 648.  On December 21, 1989, a notice of final                      
          partnership administrative adjustment (FPAA) with respect to                
          Foam’s 1982 tax year was issued to petitioner and to Richard                
          Roberts, Foam’s general partner and tax matters partner.  The               
          FPAA advised petitioner of adjustments to the 1982 Form 1065,               






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