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cattle contribution for FY 1993; and (3) $100,000 cash
contribution claimed on their respective 1995 tax returns.
In petitions filed on July 3, 1997, petitioners challenged
respondent's determinations. In answers filed on August 21,
1997, respondent reiterated the contentions set forth in the
notices of deficiency. The cases were assigned to Appeals
Officer Robert Chirich. On September 19, 1997, Officer Chirich
requested that petitioners provide substantiation for the
deductions relating to depreciation and contributions of cash and
cattle. On October 20, 1997, petitioners provided partial
substantiation for the depreciation deductions. On November 18,
1997, Officer Chirich informed petitioners' counsel that Agent
Parker would continue his examination.
On December 12, 1997, the Court granted petitioners leave to
amend their petitions. In the amendments, petitioners contended
that Salopek erroneously capitalized pecan tree pruning costs
and, in calculating its charitable contribution, undervalued the
cattle. Petitioners further contended that they were entitled to
refunds. On January 15, 1998, respondent filed answers to the
amendments, denying petitioners' contentions.
In early December 1997, Agent Parker requested
substantiation for the deductions relating to the cattle
contribution and the depreciable bases of the pecan trees. In
January 1998, he requested substantiation for the pruning costs
deduction. Between December 1997 and January 1998, petitioners
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