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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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