Mary K. Fisher and Charles F. Patterson, et al. - Page 8

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          all 19 horses by using what petitioner Charles F. Patterson                 
          considered to be the horses' combined fair market values on that            
          date.  Petitioners have stipulated that they have not provided              
          any substantiation as to the cost of any of the horses which they           
          acquired prior to 1988.  Petitioners also acquired a 20th horse             
          during 1988 and used the horse's purported cost as its                      
          depreciable basis.  Petitioners have stipulated that they have              
          not supplied any substantiation as to the cost or acquisition               
          date of this horse.                                                         
               With respect to the business equipment, machinery and                  
          equipment, nonlisted vehicles, office furnishings, and library              
          materials placed in service on January 1, 1988, petitioner                  
          calculated depreciable bases from his estimate of the fair market           
          values of the assets on that date.  With respect to the computer            
          and peripherals placed in service on January 1, 1988, petitioner            
          calculated depreciable bases from the purported cost of the items           
          in question.  Petitioners have stipulated that they have not                
          provided any substantiation as to the acquisition dates or cost             
          of the specific items of business equipment, computer and                   
          peripherals, machinery and equipment, nonlisted vehicles, office            
          furnishings, and library materials.                                         
               Petitioners placed three horses, Moonsang, Since Gussie, and           
          Puget Sound, in service on January 1, 1990.  Petitioner listed              
          cost bases attributable to the horses in the amounts of $400,               
          $700, and $800, respectively.  In addition, petitioner added a              




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