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depreciation deductions they claimed upon such breeding sheep for
the years in issue.
With respect to OGT 90, we previously concluded that
petitioners failed to offer sufficient evidence substantiating
OGT 90's alleged acquisition of 1,301 breeding sheep during 1990.
Consequently, we sustain respondent's determinations in the FPAA
that OGT 90 is not entitled to a depreciation deduction with
respect to such breeding sheep for 1991. See Rules 142(a), 240
(a).
Issue 2. Interest Deductions
As discussed supra in connection with parts E and F of Issue
1, the Court has concluded that the purported recourse promissory
notes RCR #4 and RCR #6, each issued to Barnes Ranches, were not
a valid indebtedness. Accordingly, we hold that RCR #4 and RCR
#6 are not entitled to the interest deductions they claimed for
the years in issue.
Issue 3. Certain Farm Deductions35
As discussed supra in connection with Issue 1, the Court has
concluded that RCR #4 and RCR #6 did not acquire the benefits and
burdens of ownership with respect to the breeding sheep each
claimed to have acquired from Barnes Ranches. Accordingly, we
hold that RCR #4 and RCR #6 are not entitled to the farm
deductions they claimed for the years in issue.
35On brief, petitioners conceded the deductions RCR #4, RCR
#6, and OGT 90 claimed for drought and/or trichomoniasis.
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