Robert H. Goode, Jr. and Lockie L. Goode - Page 17




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        not expense the cost of Robco’s power tools.                                  
             Mr. Goode testified that $1,820, the amount petitioners                  
        claimed as a deduction, was his conservative estimate of the cost             
        of several power tools Robco acquired during 2002, which ranged in            
        price from $2 to $300.  In view of the nature of Robco’s                      
        activities, and because we find Mr. Goode’s testimony in this                 
        regard credible, we hold that petitioners expended $1,820 for the             
        acquisition of power tools in 2002 and are therefore entitled to              
        an appropriate depreciation deduction with respect to that                    
        acquisition.  The parties shall determine the exact amount of the             
        depreciation deduction to which petitioners are entitled in their             
        Rule 155 computations.                                                        
             To reflect the foregoing,                                                

                                                Decision will be entered              
                                           for petitioners in docket                  
                                           No. 4802-06S.                              
                                                Decision will be entered              
                                           under Rule 155 in docket No.               
                                           9978-05S.                                  














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