- 49 -
was attributable to Madison Recycling.
With respect to the claimed $58,089 Madison Recycling loss,
although that loss was set forth in Statement 2, that statement
also showed the following respective claimed losses of the
following partnerships, which accounted for $131,876 of the total
claimed partnership losses of $189,965 shown in Schedule E:
Name of Partnership Partnership Loss
Kelly-Brock Drilling Partners 1981-1 $64,753
Odessey Partners 81 Limited Partnership 57,087
Matagorda Limited Partnership II 10,036
Thus, Statement 2 showed a claimed loss from the Kelly-Brock
Drilling Partners 1981-1 partnership that was greater than the
claimed $58,089 Madison Recycling loss and a claimed loss from
the Odessey Partners 81 Limited partnership that was approxi-
mately equal to the claimed $58,089 Madison Recycling loss.
With respect to the claimed Madison Recycling credits of
$114,407, neither Schedule E, which had a notation to Statement
2, nor Statement 2 referred to Form 3468, the form included with
the 1982 joint tax return in which the respective bases for any
claimed investment tax credit and any claimed business energy
investment tax credit and the computation of such respective
credits were to be detailed. Form 3468 included as part of the
joint 1982 tax return showed (1) a claimed $59,835 investment tax
credit and (2) a claimed $56,657 business energy investment tax
credit. That form did not, however, indicate the entity or
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