Greta Ann Clifton - Page 14

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          taxpayer claims a deduction based on a mileage rate.  Nash v.               
          Commissioner, 60 T.C. 503, 520 (1973); Alisobhani v.                        
          Commissioner, T.C. Memo. 1994-629.  Accordingly, we sustain                 
          respondent's disallowance of petitioner's claimed depreciation              
          arising from the truck.                                                     
               In regard to the depreciation claimed on the computer,                 
          respondent argued that petitioner did not substantiate her                  
          purchase of the computer.  To substantiate her entitlement to a             
          depreciation deduction for the computer, petitioner must                    
          establish, among other things, the computer's depreciable basis,            
          by showing the cost of the property.  Delsanter v. Commissioner,            
          supra; Kerrigan v. Commissioner, T.C. Memo. 1995-483; Greenway v.           
          Commissioner, T.C. Memo. 1980-97.                                           
               To demonstrate Orad's cost basis in the computer, petitioner           
          provided a purported bill of sale dated February 28, 1985; the              
          bill of sale shows that Knappco purchased a computer from Kansas            
          City Digital Systems.  Petitioner also provided a check made to             
          the order of Lafayette Bank for $5,985, which she claims to have            
          used to purchase a cashier's check.  Petitioner claims she then             
          gave Knappco the cashier's check in exchange for the computer.              
          Finally, petitioner produced a purported bill of sale from                  
          Knappco to Orad, which indicates that Knappco sold a Kaypro                 

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