Theresa Salopek, et al. - Page 3

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          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 $600,000             




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