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Statement 14 attached to ABC's 1988 income tax return contained
the following:
SECTION 168(F)(1) ELECTION TO EXCLUDE PROPERTY FROM ACRS
BY USE OF A METHOD OF DEPRECIATION NOT EXPRESSED IN A TERM
OF YEARS: RENTAL INVENTORY
1. NAME OF TAXPAYER: ABC RENTALS OF SAN ANTONIO
2. TAXPAYER I.D. # : 74-2334664
3. YEAR RECOVERY PROPERTY PLACED IN SERVICE: VARIOUS
4. UNADJUSTED BASIS OF THE RECOVERY PROPERTY:
$544,343
5. METHOD OF DEPRECIATION: INCOME FORECASTING
Guaranteed and ABC compiled detailed experience data with
respect to their rental units during the 1991 and 1992 calendar
years. Guaranteed and ABC's business operations and surrounding
market conditions have remained essentially unchanged from the
years at issue throughout the years in which such experience data
was derived. Due to such continuity, the parties submit that
(assuming the actual data as to Guaranteed and ABC was available
for the tax years in question) the data, if delineated, would not
vary materially from the experience data delineated from 1991 and
1992.
Each Entity's 1991 and 1992 experience data indicates that,
per category of rental units, the actual average total amount of
gross rental the Entities received under all rental contracts for
a rental unit in such category was the product of the initial
cost to an Entity of such rental unit times the following
delineated integer:
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