New Gaming Systems, Inc. - Page 13

                                       - 13 -                                         
          the income of the equipment was not forecasted in order to                  
          calculate the depreciation deduction.  Petitioner’s president               
          stated that revenue generated by the equipment dropped off after            
          the fourth or fifth quarter.  Thus, under the income forecast               
          method of depreciation, petitioner would not have depreciated the           
          machines evenly over 2 years.  We conclude that petitioner did              
          not use the income forecast method to depreciate its equipment,             
          but, rather, a term of 2 years.                                             
               In reaching all of our holdings herein, we have considered             
          all arguments made by the parties, and to the extent not herein             
          discussed, we find them to be irrelevant or without merit.                  
               To reflect the foregoing,                                              
                                                       An appropriate order           
                                                  will be issued granting             
                                                  respondent’s motion for             
                                                  partial summary judgment.           




















Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  

Last modified: May 25, 2011