- 24 - 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,Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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