ABC Rentals of San Antonio, Inc., et al - Page 10

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               The Form 4562 filed with Guaranteed's tax return for its               
          taxable year ending December 31, 1987, contains the heading on              
          line 9 "Property subject to section 168(f)(1) election."  The               
          1987 instructions for this form provide that line 9 should be               
          used to report property that the taxpayer elects, under section             
          168(f)(1), to depreciate by any method not based on a term of               
          years.  Furthermore, the instructions provide that the                      
          depreciation deduction for the property should be entered in                
          column (f) of line 9.7  However, Guaranteed left column (f) of              
          line 9 blank.  Rather, it appears the depreciation deduction for            
          the rental property has been included in column (f) of line 10--            
          "Other depreciation" where a $40,616 deduction is claimed.                  
          Guaranteed failed to indicate on its Form 4562 that it was using            
          the income forecast method of depreciation.  Nothing in                     
          Guaranteed's return indicates that it was electing the income               
          forecast method of depreciation.                                            
               ABC did not attach a separate statement to its return for              
          its taxable year ending May 31, 1987.  ABC did not include the              
          year the rental property was placed in service, nor did it                  
          include the unadjusted basis of the rental property.                        


               7See infra pp. 18-19.                                                  








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