9 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'sPage: 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