- 19 -
with respect to Madison Recycling. The only information that Mr.
Korchak provided to Mr. Sokol with respect to Madison Recycling
before that return was prepared was Schedule K-1, Partner’s Share
of Income, Credits, Deductions, Etc., that Madison Recycling
issued to Mr. Korchak (Madison Recycling 1982 Schedule K-1 issued
to Mr. Korchak).14
The information set forth in the Madison Recycling 1982
Schedule K-1 issued to Mr. Korchak was consistent with the
information that Madison Recycling reported in Form 1065, U.S.
Partnership Return of Income, for its taxable year ended December
31, 1982 (Madison Recycling’s 1982 return) that Madison Recycling
filed with the IRS on March 14, 1983. In Madison Recycling’s
1982 return, Madison Recycling claimed, inter alia, a loss of
$704,111 (Madison Recycling’s claimed $704,111 loss). In Form
3468, included as part of Madison Recycling’s 1982 return,
Madison Recycling claimed a basis of $7,000,000 for both invest-
ment tax credit purposes and business energy investment tax
credit purposes (Madison Recycling’s claimed $7,000,000 basis for
investment tax credit purposes and business energy investment tax
credit purposes).
If petitioner had asked Mr. Korchak before she signed the
14The parties stipulated and attached as an exhibit to the
parties’ stipulation of facts a copy of the 1982 joint tax return
that petitioner and Mr. Korchak filed with the IRS. That return
did not include Madison Recycling 1982 Schedule K-1 issued to Mr.
Korchak.
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011