- 2 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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