ABC Rentals of San Antonio, Inc., et al - Page 19

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               accompanying the return for the taxable year, the statement            
               shall--                                                                
                         (A) Contain the name, address and taxpayer                   
                    identification number of the electing taxpayer,                   
                         (B) Identify the election,                                   
                         (C) Indicate the section of the Code (or, if the             
                    provision is not codified, the section of the Act)                
                    under which the election is made,                                 
                         (D) Specify, as applicable, the period for which             
                    the election is being made and/or the property or other           
                    items to which the election is to apply, and                      
                         (E) Provide any information required by the                  
                    relevant statutory provisions and any information                 
                    necessary to show that the taxpayer is entitled to make           
                    the election.                                                     
               A.   Guaranteed                                                        
               Guaranteed did not meet the requirements for the tax year              
          ending December 31, 1987.  Guaranteed did attach a statement--              
          Statement 2--to its tax return for the taxable year ending                  
          December 31, 1987.  However, the statement did not comply with              
          the requirements of Revenue Procedure 87-57, supra, or section              
          5h.5, Temporary Tax Reform Act of 1986 Election Regs., supra.               
          The only item of 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.              
          Nor did it refer to section 168(f)(1) or to any other provision             
          of the Code.                                                                
               Petitioners rely on section 1.168-5(e)(3), Proposed Income             
          Tax Regs., 49 Fed. Reg. 5968 (Feb. 16, 1984).  However, we note             







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