- 54 - return that $57,750 of the claimed $59,835 investment tax credit was attributable to Madison Recycling and that the claimed $56,657 business energy investment tax credit was attributable to Madison Recycling. With respect to the claimed $58,089 Madison Recycling loss, we disagree with respondent’s contention that that claimed loss was large enough to put petitioner on notice that further inquiry was warranted to determine whether it was proper. As discussed above, Statement 2 included with the 1982 joint tax return 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 approximately equal to the claimed $58,089 Madison Recycling loss. We have found that the amount of the claimed $58,089 Madison Recycling loss would not have made that claimed loss stand out in relationship to the other partner- ship losses claimed in Statement 2. Even if, as respondent argues, both the claimed $58,089 Madison Recycling loss and the claimed Madison Recycling credits of $114,407 had been “clearly set forth in a schedule attached to the return”, as discussed above, at the time petitioner signed the 1982 joint tax return she must have had sufficient knowledge of the circumstances of the transactions in which Madison Recy- cling engaged that resulted in the understatement in that returnPage: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
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