Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 4




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          Schedule F deductions as follows:  (1) The partnership activities           
          constituted a series of sham transactions lacking economic                  
          substance; (2) the partnership did not actively engage in the               
          trade or business of farming; and (3) the partnership did not pay           
          or incur any bona fide trade or business expenses during the                
          taxable period, or, if the partnership did pay or incur expenses,           
          the partnership did not establish that these were ordinary and              
          necessary trade or business expenses currently deductible under             
          section 162.                                                                
               In the FPAA, respondent set forth alternative positions                
          based on his determination that the partners were not entitled to           
          deduct their proportionate shares of the partnership’s losses               
          because they were not “at risk”, within the meaning of section              
          465, or did not have sufficient adjusted basis in their                     
          partnership interests.  See sec. 704(d).  Respondent also reduced           
          the partnership’s tax preference items by disallowing qualified             
          investment expenses of $9,973,739.                                          
               In the petition, the petitioning partners assigned error to            
          all of respondent’s adjustments and, with respect to the                    
          disallowance of the Schedule F deductions, averred the following:           
          (1) The partnership incurred and paid ordinary and necessary                
          expenses in the conduct of its trade or business of farming, in             
          an amount not less than the amount claimed by the partnership,              
          (2) the partnership engaged in a bona fide farming activity,                






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