- 3 - include petitioners' 1994 and 1995 tax returns and Salopek's FY 1994 and FY 1995 tax returns. Salopek's FY 1993 tax return included a $600,000 charitable deduction relating to a contribution of cattle and a $173,338 depreciation deduction. Salopek's FY 1994 and FY 1995 tax returns included depreciation deductions of $211,438 and $239,813, respectively. As shareholders of Salopek, petitioners included their allocable share of Salopek's ordinary income and charitable contribution on their 1993, 1994, and 1995 individual tax returns. In addition, each petitioner deducted a $100,000 charitable contribution of cash in 1995 (i.e., the cash contributions totaled $400,000). During the examination, Agent Parker requested Salopek's depreciation schedules and substantiation for the charitable contributions of cash and cattle. Petitioners did not provide substantiation for the cattle contribution but did provide the depreciation schedules and substantiation for the cash contributions. After reviewing the depreciation schedules, Agent Parker requested, but did not receive, substantiation for the depreciable bases of certain pecan trees. On April 8, 1997, respondent mailed to petitioners notices of deficiency relating to 1993, 1994, and 1995. Respondent disallowed, for lack of substantiation, each petitioner's: (1) Allocable share of Salopek's depreciation deductions for FY 1993, FY 1994, and FY 1995; (2) allocable share of Salopek's $600,000Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011