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to a depreciation deduction, the taxpayer must show that the
property was used in a trade or business (or other profit-
oriented activity). In addition, the taxpayer must establish the
property's depreciable basis, by showing the cost of the
property, its useful life, and the previously allowable
depreciation. E.g., Delsanter v. Commissioner, 28 T.C. 845, 863
(1957), affd. 267 F.2d 39 (6th Cir. 1959).
In her 1985 Federal income tax return, petitioner claimed a
depreciation deduction of $4,495. Petitioner computed the
claimed deduction as follows:
1976 Chevrolet truck $825
1984 Mark twain boat 1,320
Kaypro 16 computer 2,150
Petitioner's home 200
Total 4,495
Respondent disallowed this amount in full. Subsequently,
petitioner conceded that she was not entitled to deduct a
depreciation expense in the amount of $1,320 in connection with a
1984 Mark Twain boat, since the boat was never used in a trade or
business. Therefore, the amount at issue is $3,175 ($4,495 less
$1,320), which includes depreciation claimed on the truck, the
computer, and petitioner's home.
In addition to claiming depreciation on the truck,
petitioner also claimed a deduction based on the applicable
mileage rate. Respondent allowed a portion of such deduction.
See supra p. 12. A depreciation deduction is not allowed where a
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