Interhotel Company, Ltd. - Page 31




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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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