- 4 - 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, petitionersPage: Previous 1 2 3 4 5 6 7 8 9 Next
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