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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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Last modified: May 25, 2011