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Unless otherwise provided, section references are to the
Internal Revenue Code in effect for 1996. References to
petitioner are to Bernard William Hvidding.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners resided in Kapolei, Hawaii, when they filed
their petition. In 1996, petitioner was a social worker with the
Department of Human Services of the State of Hawaii.
B. Hawaii Environmental Holdings
Hawaiian Environmental Holdings (HEH) is a business trust.
HEH’s minutes provide that the trustees have complete discretion
to distribute tax credits and depreciation to its beneficiaries.
C. The Solar Hot Water System
Petitioners purchased their home in Kapolei in 1995. In
1996, Jeff Davis (Davis), a salesman for Mercury Solar, an
organization engaged in the sale of solar energy heating systems,
asked petitioner if he wanted to have a solar water heating
system installed in his home. Davis said that petitioner could
either: (a) Buy a solar water heating system to be installed in
his home by Mercury Solar, or (b) buy only the energy produced by
a solar water heating system owned by HEH and installed in his
home. Petitioner chose to buy only the energy.
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Last modified: May 25, 2011