- 5 - Purchase Components which gave petitioner the following three options at the end of the initial term of the SEP: (1) Extend the term for an additional 61 months at a cost of $1 per month; (2) purchase the solar water heating system at its current price; or (3) have HEH remove the system. On a date not stated in the record, petitioner extended the term for 61 months. E. Petitioners’ 1996 Return Petitioners claimed an energy credit of $536 (10 percent of $5,355)1 on Form 3468, Investment Credit, attached to their 1996 Federal income tax return. Petitioners attached to their return a Schedule K-1, Beneficiary’s Share of Income, Deductions, Credits, etc., issued to petitioner by HEH. The Schedule K-1 indicates that HEH allocated $535 to petitioner as an energy credit, but it does not indicate that HEH allocated any income to petitioner for 1996. F. The Notice of Deficiency On March 21, 2000, respondent issued a notice of deficiency to petitioners in which respondent determined that petitioners were not entitled to an energy tax credit because: (a) The energy leasing contract was in substance the purchase by petitioner of solar equipment, and (b) petitioner received no income as a beneficiary of the HEH trust in 1996 and thus was not 1 The exhibits show that HEH agreed to pay Mercury Solar $5,325. The $30 difference between $5,355 and $5,325 is not explained in the record.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011