- 31 - papers, which reflected how the amount of partnership minimum gain would be derived. Petitioner’s accountant substantiated these figures through his testimony. We found the accountant’s work papers both accurate and internally consistent and the accountant’s testimony credible. We are not persuaded otherwise by respondent’s assertion that petitioner’s work papers are inconsistent with Schedule L of the subsidiary partnerships’ tax returns. Respondent correctly maintains that the amount of depreciation for Landmark reflected on the work papers for 1990 exceeds the amount reflected on the balance sheets attached to Form 1065, U.S. Partnership Return of Income, for the same year. Petitioner, however, has explained that the discrepancy results from utilizing highly accelerated forms of depreciation then available for real estate on the accountant’s work papers, while the balance sheets for Landmark, included on its returns, were book balance sheets reflecting slower depreciation rates. A schedule entitled “tax depreciation” in Form 1065 substantiates the use of depreciation schedules, which produced higher figures than those on the balance sheets reflected on Schedule L of the same return. Moreover, the amounts of claimed depreciation set forth in Forms 1065, U.S. Partnership Return of Income, for 1989, 1990, and 1991 are identical to the figures utilized in the accountant’s work papers used to compute both Landmark’s minimum gain and IHCL’s share of that minimum gain. InPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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