- 19 - the racing and breeding horses that Kildare Timmy distributed to him. In that explanatory statement, petitioners claimed the following, inter alia, with respect to the sale of those nine horses: ORDINARY GAINS AND LOSSES Cost Gain Description Date acquired Date sold Sales price or basis or (loss) Idealists Hanover 01/01/98 04/01/98 $2,500 $4,339 ($1,839) Brief Wars 01/01/98 11/01/98 12,750 110,621 2,129 Western Skylark 01/01/98 11/01/98 5,000 14,871 129 Rare Guy 01/01/98 11/01/98 1,500 15,279 (3,779) Overture Siera 01/01/98 06/01/98 0 3,319 (3,319) Happening Hanover 01/01/98 05/01/98 1,000 3,883 (2,883) Yankee Skylark 01/01/98 11/01/98 1,200 11 1,199 Overture Hanover 01/01/98 06/01/98 0 911 (911) Vidalita Hanover 01/01/98 06/01/98 1,616 3,883 (2,267) Total to Form 4797, Part II, Line 10 25,566 37,107 (11,541) 1There is an unexplained discrepancy between the cost or basis that petitioners claimed in petitioners’ 1998 return with respect to each of the four horses Brief Wars, Western Skylark, Rare Guy, and Yankee Skylark that Kildare Timmy distributed to Mr. Ramsburg and the amount that Kildare Timmy reported in its 1998 partnership return as the gross sales price for which it allegedly sold each such horse to Mr. Ramsburg. It is petitioners’ position that Mr. Ramsburg purchased each of the above-referenced horses from Kildare Timmy for a price equal to Kildare Timmy’s adjusted basis in each such horse as reflected in Kildare Timmy’s books and records. Thus, under petitioners’ position, Mr. Ramsburg’s cost or basis in each of the four horses in question on the date on which Kildare Timmy distributed those horses to him should have been equal to the price that he claimed he paid for each such horse. However, Kildare Timmy reported in its 1998 partnership return the following gross sales price, and petitioners reported in their 1998 return the following cost or basis, with respect to each of those horses: Gross sales price Cost or basis reported in 1998 reported in partnership petitioners’ 1998 Horses return return Brief Wars $2,121 $10,621 Western Skylark 2,202 4,871 Rare Guy 5,029 5,279 Yankee Skylark 0 1 Thus, in petitioners’ 1998 return, petitioners claimed a significantly higher cost or basis in each of Brief Wars and Western Skylark and a higher cost or basis in each of Rare Guy and Yankee Skylark than the gross sales price that Kildare Timmy claimed in its 1998 partnership return it received for each such horse.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011