- 22 - 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 thePage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011