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Michael Thompson, Martin M. Loring, and Lori J. Sellers, for
petitioner.
Robert M. Morrison, Michael C. Prindible, and Todd A. Ludeke
for respondent.
HALPERN, Judge: By notices of final partnership
administrative adjustment dated April 28, 1997, respondent made
adjustments to partnership returns filed by Clajon Gas Co., L.P.
(Clajon), for taxable years ending December 31, 1990, September
25, 1991, December 31, 1991, and June 30, 1992 (the audit years).
Taking into account issues and items resolved by the parties, the
sole adjustments in dispute are respondent’s adjustments reducing
Clajon’s deduction for “pipeline depreciation”, as follows:
Tax Year Ended Adjustment
12/31/90 $7,920,799
9/25/91 19,644,092
12/31/91 4,372,916
6/30/92 12,187,347
The issue for our decision is the proper cost recovery period to
be used by Clajon in determining its depreciation deductions for
the property in question.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Petitioner bears the burden of proof. Rule 142(a).
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