10 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 disallowedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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