- 15 - units to third parties by category, such percentage being equal to the ratio such total sales proceeds bore to the total initial purchase price of all rental units in that category, was as follows: Category Percentage Guaranteed ABC Appliances 2.0 2.7 Televisions Less than 1 5.5 Furniture 2.3 2.4 Stereos Less than 1 Less than 1 Video Cassette Recorders Less than 1 Less than 1 The total initial cost of rental units acquired during the years 1987 and 1988 and which remained in Guaranteed's rental inventory as of the end of the years was $142,173.71 and $117,812.45, respectively. The total initial cost of rental units acquired during the tax periods ending May 31, 1987, December 31, 1987, and December 31, 1988, and which remained in ABC's rental inventory as of the end of the periods was $273,435.20, $137,102.89, and $328,557.04, respectively. OPINION The U.S. Court of Appeals for the Tenth Circuit has directed us to determine: (1) Whether petitioners made a proper election under section 168(f) and, (2) if a proper election was made under section 168(f), whether petitioners improperly applied the income forecast method because they did not accurately forecast thePage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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