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cattle, Mr. Daily asked the ranch manager to sign a statement
agreeing or disagreeing with the numbers of cattle Mr. Daily
determined were present. With just a few exceptions, all of the
ranch managers at each location agreed with Mr. Daily’s cattle
numbers. During the cattle count he conducted, Mr. Daily further
had asked Jay Hoyt to disclose whether there were any additional
locations where other cattle might be located. However, in his
witness statement submitted to the District Court on or about
January 23, 1993, Jay Hoyt maintained that the specific locations
for the cattle had been provided to respondent and indicated that
he saw no reason why the cattle count could not go on.
In the respective FPAA’s issued to DF #1, SGE 82-1, DGE 84-
3, SGE 84-5, DGE 86-2, TBS 89-1, and TBS 90-1, respondent, among
other things, determined that the partnerships had failed to
substantiate many of their claimed deductions. For instance,
with respect to the depreciation deduction DF #1 claimed on its
breeding cattle for its year ended September 30, 1991, the FPAA
issued to DF #1 for that year states, in pertinent part:
It has been determined that * * * [DF #1] is not
entitled to the depreciation deduction claimed on its
Schedule F because the partnership has not established:
(1) That it possessed depreciable assets which it used
for the production of income or in carrying on a trade
or business; (2) the accumulated depreciation and
depreciable basis of its assets; and (3) the relevant
date and proper computation method.
In the FPAA’s issued to Management for its years ended
September 30, 1987 through 1990, respondent, among other things,
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