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Issue 6. Accounting and Tax Return Preparation Fees Deductions
SGE 82-1, DGE 84-3, SGE 84-5, and TBS 90-1 each claimed
deductions for accounting and tax return preparation fees for its
1992 tax year.
Petitioners have failed to present sufficient evidence
substantiating that SGE 82-1, DGE-84-3, SGE 84-5, and TBS 90-1
paid such accounting and tax preparation fees. Consequently, we
sustain respondent’s determinations in the FPAA’s disallowing the
deductions these foregoing partnerships claimed for the 1992 tax
year in issue. See Rules 142(a), 240(a).
Issue 7. Investment Tax Credits
Petitioners claim that DGE 84-3 and SGE 84-5 are entitled to
investment credits for 1987 for cattle each partnership purchased
in 1984. They maintain that under the earlier settlement
concluded for these partnerships for 1984 through 1986, the
cattle were excluded and not depreciated by each partnership for
those years. Petitioners argue that these “excluded” cattle were
thus placed in service in 1987 and that DGE 84-3 and SGE 84-5 are
entitled to investment credits under certain transition rules
provided to section 38 concerning property purchased under a
binding contract.
As discussed supra in connection with Issue 1, the Court
concluded DGE 84-3 and SGE 84-5 did not acquire the benefits and
burdens of ownership with respect to the breeding cattle each
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