Greta Ann Clifton - Page 15

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          computer to Orad for $5,985.  This document was purportedly                 
          signed by K. E. Haslow (Haslow).5                                           
               Respondent argues that the purported bill of sale from                 
          Knappco to Orad is not authentic.  To support this assertion,               
          respondent introduced a letter from Haslow, wherein Haslow                  
          indicates that Knappco did not sell a Kaypro computer to                    
          petitioner.  Furthermore, respondent contends that the check                
          payable to Lafayette Bank was in fact a principal payment for               
          petitioner's mortgage on her house, since the notation on the               
          check reads "For 599 Hwy 224", which is the address of a house              
          petitioner purchased in 1985.                                               
               We find that petitioner has failed to substantiate her cost            
          basis in the Kaypro computer.  The bill of sale from Kansas City            
          Digital Systems lists the purchaser as Knappco, not petitioner or           
          Orad.  And, most importantly, petitioner did not produce a copy             
          of the cashier's check allegedly used to purchase the computer              
          from Knappco; rather, she testified that her attorney in her                
          criminal case had a copy of such check.  Since petitioner cannot            
          establish that she purchased the Kaypro computer, we hold that              
          she may not claim a deduction for its depreciation.  See                    
          Delsanter v. Commissioner, supra; Kerrigan v. Commissioner,                 
          supra; Greenway v. Commissioner, supra.                                     

          5  Haslow was the vice president of administration for Mercury              
          Metal Products, Inc.  Knappco was a division of Mercury Metal               
          Products, Inc. in 1985.                                                     

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