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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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