River City Ranches #4 - Page 85

                                       - 23 -                                         
          depreciation and other deductions claimed on the returns of the             
               In the respective FPAA's issued to RCR #4, RCR #6, and OGT             
          90, respondent, among other things, determined that the                     
          partnerships had failed to substantiate many of their claimed               
          deductions and thus disallowed those deductions.  For instance,             
          with respect to the depreciation deduction RCR #4 claimed on its            
          breeding sheep for 1987, the FPAA issued to RCR #4 for that year            
          states, in pertinent part:                                                  
               It has been determined that River City Ranches No. 4,                  
               J.V., partnership is not entitled to the depreciation                  
               expense as reported on the partnership Schedule F since                
               the partnership has not established the cost or                        
               adjusted basis or existence of the assets, including                   
               but not limited to animals, allegedly acquired by the                  
               partnership during the taxable year 1984, or that if                   
               acquired by the partnership during that year, that the                 
               assets were placed in service during that year  * * *                  
               RCR #4, RCR #6, and OGT 90 filed respective petitions                  
          seeking review of the FPAA's that had been issued to them.  In              
          its pleadings, RCR #4 originally maintained that it had acquired            
          a breeding flock of 1,353 sheep on February 1, 1984.                        
          Subsequently, petitioners asserted that RCR #4 had acquired a               
          breeding flock of 1,468 breeding sheep on that date.  Similarly,            
          in its amended petition, OGT 90 alleged that it had originally              
          purchased a breeding flock for $2,932,753 in 1990, and this                 
          breeding flock was placed in service in 1991.                               

Page:  Previous  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  Next

Last modified: May 25, 2011