- 8 - basis of these assumptions, the economic projections show a net cashflow of $2,453,398. The income projections in the PPM are not discounted to present value. According to the PPM, depreciation on the EMS was expected to total $1,478,571 for 1980. This was based on Sav-Fuel’s use of the Class Life Asset Depreciation Range method to depreciate the EMS on a double declining basis over 7 years. The PPM also states that the partnership anticipated approximately $2,070,000 in 1980 for investment tax credits and energy credits. The PPM states that to the extent that fuel prices do not continue to increase through 2005 at the rate projected, Sav-Fuel will be unable to achieve the gross income and return to its limited partners as set forth in its economic projections. The PPM also recognizes that the development of new processes or technology could result in the possible obsolescence of the EMS. Over 30 of the past 35 years, petitioner has worked as a stockbroker and investment banker. At the time of his investment in Sav-Fuel, petitioner had no knowledge of the partnership other than that obtained from reviewing the PPM. Petitioner has no personal knowledge of the EMS. Petitioner and his former wife’s jointly filed 1981 Federal income tax return was mailed to respondent on March 11, 1983. On the return, petitioner claimed a deduction of $18,956, his distributive share of the partnership losses from Sav-Fuel. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011