Bruce Selig and Elaine Selig - Page 11

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               improvements and reasonably foreseeable economic                       
               changes.  Among these causes are normal progress of the                
               arts and sciences, supersession or inadequacy brought                  
               about by developments in the industry, products,                       
               methods, markets, sources of supply, and other like                    
               changes, and legislative or regulatory action.  * * *                  
               In Columbia Malting Co. v. Commissioner, supra at 1001, we             
          said:                                                                       
                    In order that the taxpayer may be entitled to the                 
               obsolescence deduction in the years involved, there                    
               must have been substantial reasons for believing that                  
               the assets would become obsolete prior to the end of                   
               their ordinary useful life, and second, it must have                   
               been known, or believed to have been known, to a                       
               reasonable degree of certainty, under all the facts and                
               circumstances, when that event would likely occur.                     
               * * *                                                                  
          Under section 168(a), we need not concern ourselves with the                
          second part of that test (when obsolescence would occur), since             
          we need not determine the actual useful life of the property.  As           
          to the first part of the test, we assume that the "ordinary"                
          useful life of the exotic automobiles in petitioner's trade or              
          business (as show cars) was indeterminable.  Petitioners have               
          introduced no evidence from which we could find that the exotic             
          automobiles were subject to wear and tear or exhaustion.                    
          Nevertheless, we are convinced that the exotic automobiles had a            
          limited useful life as show cars.                                           
               The exotic automobiles are state-of-the-art, high technology           
          vehicles with unique design features or equipment.  Petitioner              
          testified that show cars such as the exotic automobiles:                    
               are state of the art and within three years or four                    
               years, five years, there could be new cars that are                    




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