River City Ranches #4 - Page 84

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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               
          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                
               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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