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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. In
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