Theresa Salopek, et al. - Page 4

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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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