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taxpayers a depreciation deduction for the exhaustion and wear
and tear of property used in a trade or business or held for the
production of income. Property becomes depreciable beginning
when it is placed in service. Piggly Wiggly S., Inc., v.
Commissioner, 84 T.C. 739, 745 (1985), affd. on another issue 803
F.2d 1572 (11th Cir. 1986); Clemente v. Commissioner, T.C. Memo.
1985-367; sec. 1.167(a)-10(b), Income Tax Regs. Property is
considered placed in service when it is ready and available for a
specifically assigned function. Piggly Wiggly S., Inc., v.
Commissioner, supra; Williams v. Commissioner, T.C. Memo. 1987-
308; sec. 1.167(a)-11(e)(1)(i), Income Tax Regs.
At trial, petitioners were unable to identify the asset for
which they claimed the subject depreciation deduction. Thus,
petitioners failed to substantiate their entitlement to the
claimed depreciation deduction. Accordingly, the Court holds
that petitioners are not entitled to a $22 depreciation deduction
in connection with Spanky's. Respondent is sustained on this
issue.
The final issue for decision is whether petitioners are
liable for the accuracy-related penalty, under section 6662(a),
for negligence or disregard of rules or regulations in the amount
of $2,194.60. Section 6662(a) provides that, if it is applicable
to any portion of an underpayment in taxes, there shall be added
to the tax an amount equal to 20 percent of the portion of the
underpayment to which section 6662 applies. Section 6662(b)(1)
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