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deduction with respect to her claimed share of the section 179
expense deduction claimed by Master Plan. We reject this claim
for several reasons. First, the Neon does not constitute section
179 property with respect to Master Plan because it did not
acquire the Neon by purchase. Sec. 179(d)(1) and (2). The
record clearly shows that petitioner purchased the Neon with her
personal funds in her own name. There is no evidence or claim
that the Neon was later conveyed to or purchased by Master Plan
by the end of 1994. Second, we are not convinced that the Neon
was used in Master Plan's business. Sec. 179(d)(1). Petitioner
did not introduce any documentary or testimonial evidence at
trial which proves that the Neon was so used. Third, even if we
were to assume that the Neon qualifies as section 179 property
with respect to Master Plan's business, Master Plan is not
entitled to a section 179 expense deduction for 1994 because it
did not have any taxable income in 1994. Sec. 179(b)(3). It
follows that there is no section 179 expense deduction which may
be passed through to petitioner as a shareholder on her Schedule
K-1 and her Schedule E for 1994. Sec. 1.179-2(c)(2)(i), (3)(i),
Income Tax Regs.
Nonetheless, petitioner maintains that she is entitled to a
section 179 expense deduction for the cost of the Neon. We
gather from the record that petitioner is now claiming that the
Neon was purchased for and used in a business other than Master
Plan's. However, she has not proved or even explicitly argued
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