ABC Rentals of San Antonio, Inc., et al - Page 9

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          rental units initially acquired by an Entity through purchase               
          from third parties and rented for the first time and for rental             
          units rented by an entity on a subsequent rental contract, each             
          year's depreciation deduction was equal to the cost of the rental           
          units multiplied by a fraction.  The numerator of the fraction              
          was the current year's income from that rental unit.  The                   
          denominator of the fraction was 300 percent of the rental unit's            
          initial cost, which was the amount of total gross rental that               
          would be received if the initial rental contract on such rental             
          went to term.                                                               
               Guaranteed attached Statement 2 to its tax return for the              
          taxable year ending December 31, 1987.  The only information                
          Statement 2 provided was that the type of property being                    
          depreciated was "RENTAL UNITS".  The statement did not say that             
          Guaranteed made an election of the income forecast method or of             
          any other method of depreciation.  Rather, the Statement 2                  
          "Method" column was left blank.  Nor did it refer to section                
          168(f)(1) or to any other provision of the Code.  Statement 2 did           
          not provide the year the rental property was placed in service--            
          in the "Date Acquired" column, Statement 2 says "VAR".  In                  
          addition, Statement 2 did not provide the unadjusted basis of the           
          rental property--the "Cost or Basis" column is blank.                       








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