5
partnership and on behalf of each of six limited partners,
including petitioner, as attorney-in-fact.
The partnership filed a Form 1065, U.S. Partnership Return
of Income, for the taxable year ending December 31, 1978. The
return reports that the partnership started business on January
20, 1978. The Form 1065 shows total partnership capital of
$3,100.
The Schedules K-1 attached to the partnership return
allocated the total purchase price indicated on the January bill
of sale as the basis of the cattle to the limited partners. The
basis of new investment property with a life of 7 or more years
was reported as $1,203,020. The cost of used investment property
with a life of 7 or more years was reported as $78,600. The
Schedules K-1 reflect the following partnership interests and
allocations:
Profit Loss Basis New Cost Used
Capital Sharing Sharing Investment Investment
Partner Account Ratio Ratio Property Property
Daniel Gallagher $250 7% 8% $ 65,500 -0-
William Bingston 500 20% 23% 337,800 -0-
George Coward 500 12% 14% 165,200 -0-
John D. Gaskins 500 -- -- 222,800 -0-
Bobby D. Chiles 500 -- -- 267,520 -0-
Alonzo Corwin 500 15% 18% 144,200 78,600
W. Jay Hoyt III 100 15% -- -- --
Totals 2,850 1,203,020 78,600
Petitioner's sharing ratios were reported incorrectly on the
Schedule K-1 for 1978. As of December 31, 1978, petitioner's
correct share of partnership capital was 18.182 percent.
Petitioners claimed investment tax credit basis for new
property with a life of 7 or more years in the amount of $165,200
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011