Greta Ann Clifton - Page 16

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               Finally, in regard to petitioner's claimed deduction for the           
          depreciation of her home, respondent argued that petitioner was             
          claiming a double deduction for this depreciation.  It is well              
          settled that the Internal Revenue Code should not be interpreted            
          to allow the equivalent of a double deduction.  United States v.            
          Skelly Oil Co., 394 U.S. 678, 684 (1969).  Here, petitioner                 
          claimed, and respondent allowed, a depreciation deduction arising           
          from petitioner's home in the computation of her home office                
          expense.  Petitioner is not allowed to claim a deduction twice.             
          Therefore, we affirm respondent's determination as to this issue.           
               D.  Repair and Maintenance Expenses                                    
               Respondent determined that petitioner was not entitled to              
          claim a Schedule C deduction for repairs and maintenance in the             
          amount of $852.                                                             
               Petitioner claims that $531 of the claimed deduction arises            
          from a computer service contract between Orad and Kansas City               
          Digital Systems.  To substantiate payment for the service                   
          contract, petitioner presented the check, discussed above, made             
          to the order of Lafayette Bank for $5,985.  Petitioner claims she           
          used this check to purchase both the computer and the service               
          contract.  Also, in support of the claimed deduction, petitioner            
          presented a service contract.  Petitioner did not present any               
          evidence in regard to the remaining $321 of her claimed deduction           
          ($852 minus $531).                                                          

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