Camille D. Sands, et al. - Page 10

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          operation, but those problems were not so severe as to prevent              
          the system from being placed in service.                                    
               Respondent argues that we should disregard Lone Star's                 
          $2,621,798 cost basis in the system, because there were no arm's-           
          length negotiations over the purchase price.  To support this               
          argument, respondent notes that Murphy served as legal counsel              
          for Micro-Bio when Micro-Bio acquired the chlor-alkali system               
          technology from Eltech.  There is no evidence that Murphy                   
          influenced the terms of the transaction between Micro-Bio and               
          Eltech.  Before Lone Star agreed to purchase the chlor-alkali               
          system from Eltech, Murphy reviewed financial projections                   
          prepared by Micro-Bio.  After reviewing the information at his              
          disposal, Murphy concluded that the purchase of the chlor-alkali            
          system was a sound investment.  While the matter is not free from           
          doubt, we find that Lone Star acquired the chlor-alkali system in           
          an arm's-length transaction.                                                
               Sands is entitled to her share of the Lone Star depreciation           
          deduction in each of the taxable years 1984, 1985, and 1986 based           
          on the foregoing facts.                                                     
               2.  Interest Deductions and Other Deductions                           
               Lone Star reported interest expenses of $70,360 and $48,786            
          for taxable years 1984 and 1985, respectively.  Lone Star                   
          reported "other deductions" of $19,227 and $38,612 for taxable              
          years 1984 and 1986, respectively.  Sands deducted her                      
          proportionate shares of these items, and respondent disallowed              




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