Camille D. Sands, et al. - Page 9

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               Under the terms of the settlement, Eltech forgave and                  
          canceled payment of the $2,069,656 balance due from Lone Star.              
          At the time of the settlement, Lone Star's adjusted basis in the            
          chlor-alkali system was $1,019,104 ($2,621,798 cost basis less              
          $1,602,694 of depreciation deductions).  At the direction of                
          Eltech, Lone Star, "as beneficial owner", transferred full                  
          ownership of the chlor-alkali system to Electro and agreed to               
          relieve Electro of all obligations under the Lone Star-Electro              
          lease.  Electro agreed to pay Lone Star some amount, which was              
          determined by respondent to be $258,986, but Electro never                  
          fulfilled that obligation.                                                  
          B.   Petitioner Sands                                                       
               Respondent argues that Sands deducted amounts in excess of             
          her distributive shares of the partnership items.  Sands owned a            
          5-percent, 7-percent, and 7.5-percent partnership interest in               
          Lone Star during the taxable years 1984, 1985, and 1986,                    
          respectively, and her distributive share of the partnership items           
          for each taxable year is limited accordingly.                               
               1.  Depreciation Deductions                                            
               Respondent argues that Sands is not entitled to depreciation           
          deductions, because the chlor-alkali system was never placed in             
          service.  Electro installed and operated the chlor-alkali system            
          in 1984, and we find that the system was placed in service at               
          that time.  We recognize that problems plagued the system's                 






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