Andrew J. and Marilyn Welch - Page 5




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               In 1982 and 1983, petitioners paid a total of only $39,170             
          and $50,000, respectively, in estimated and withheld Federal                
          income taxes.                                                               
               On petitioners’ jointly filed Federal income tax returns for           
          1982 and 1983, petitioners reported $649,177 and $1,027,000 in              
          income from petitioner’s medical practice, and petitioners                  
          claimed net losses of $575,171 and $671,937, respectively,                  
          relating to petitioners’ various tax-sheltered partnership                  
          investments, including losses relating to Blythe II of $83,732              
          and $4,024, respectively, for those years.                                  
               On audit, respondent disallowed the claimed losses relating            
          to petitioners’ investment in Blythe II.  William G. Kellen, the            
          tax matters partner of Blythe II, initiated a proceeding under              
          the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L.               
          97-248, 96 Stat. 324, 648, and signed a stipulation to be bound             
          by the decision entered in Utah Jojoba I Research v.                        
          Commissioner, T.C. Memo. 1998-6 (Utah I).                                   
               As a result of the final resolution of Utah I (wherein                 
          claimed section 174 research and experimental expenses and losses           
          similar to those claimed by Blythe II were disallowed), the tax             
          deficiencies relating to petitioners’ investment in Blythe II are           
          conceded by petitioners.                                                    










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