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depreciation and other deductions claimed on the returns of the
partnerships.
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.
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