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Petitioner had three vehicles in 1985. She testified that
she claimed deductions only for the expenses related to two of
her vehicles, the 1965 Mustang and the truck. According to
petitioner, she used both the 1965 Mustang and the truck for
business purposes and personal purposes. Respondent determined
that petitioner would qualify for the standard mileage deduction
and allowed such deduction for 1985. We believe that petitioner
used the 1965 Mustang in her Avon business and the truck in the
Orad business; however, petitioner presented no evidence as to
what portion of her claimed expenses was for business purposes
and what portion was for personal purposes. Therefore, we
sustain respondent's determination with respect to this item.
See Cobb v. Commissioner, supra; Shelley v. Commissioner, T.C.
Memo. 1994-432; Cady v. Commissioner, T.C. Memo. 1990-474.
C. Depreciation
Respondent determined that petitioner was not entitled to
the depreciation deduction claimed on her 1985 Federal income tax
return. Petitioner asserts that such deduction is allowable.
Section 167 provides, in part, for a depreciation deduction
with respect to property used in a trade or business.
Depreciation allows the taxpayer to recover the cost of the
property used in a trade or business or for the production of
income. United States v. Ludey, 274 U.S. 295, 300-301 (1927);
Southeastern Bldg. Corp. v. Commissioner, 3 T.C. 381, 384 (1944),
affd. 148 F.2d 879 (5th Cir. 1945). To substantiate entitlement
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