- 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 NextLast modified: May 25, 2011