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RCR #6's returns for some of the years in issue reflect that
it originally claimed depreciation and investment tax credit on a
"Breeding Flock" placed in service on January 5, 1986, for which
its stated cost or other basis was $1,868,139. RCR #6
depreciated this breeding flock over a 5-year period.
OGT 90's return for 1991 reflects it claimed depreciation on
"1 sheep breeding" acquired on January 1, 1991, for which its
depreciable basis was $1,952,076. OGT 90 depreciated this "1
sheep breeding" over a 5-year period.
On their respective returns for the years in issue, RCR #4,
RCR #6, and OGT 90 also claimed deductions for interest, other
farm expenses, guaranteed payments, and losses for sheep
suffering from drought and/or trichomoniasis. The partnerships
claimed additional deductions for IRA contributions and other
expenses.
F. Respondent's Examinations of the Nine Sheep Partnerships; the
FPAA's Issued to RCR #4, RCR #6, and OGT 90; RCR #4's, RCR #6's,
and OGT 90's Respective Petitions; Certain Pretrial Discovery
Conducted; and Certain Evidence Offered During and After the
Trial
Respondent commenced examinations of various returns filed
by the nine sheep breeding partnerships, including the returns of
RCR #4, RCR #6, and OGT 90 for the years in issue. During these
examinations, respondent asked the partnerships and their
representatives, among other things, to substantiate the
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