- 5 - Ranches to the partnerships; promissory notes from the partnerships to Ranches; and bills of sale from the partnerships to Ranches. The partnerships reported income recognized on the transfer of cattle to Ranches in payment of principal and interest as gain under section 1231. Respondent adjusted this item to zero on the final partnership administrative adjustments issued to each partnership. Pursuant to the agreement, the numbers of cattle subject to depreciation by the partnerships for the taxable years in issue were reduced. All cattle were subject to revised valuation as well. As a result, the amounts of principal due on the notes payable to Ranches for the cattle purchased were treated as reduced, and respondent recalculated the annual interest due based on these amounts according to the provisions of the agreement. This interest was to be computed on an original principal balance of $4,000, the settled cost basis of the breeding cattle per head, times the number of cattle in service during the first year of each partnership. The agreement provides that this new principal amount is the amount of partnership debt to be treated as personally assumed by the partners. Schedule F Income In part, the agreement provides:Page: 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