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that there is no limit on the useful life of a restored car or
other vehicle as a museum object." Id., 661 F.2d at 207. In
Simon v. Commissioner, 103 T.C. at 264, we acknowledged that, to
qualify as recovery property, in the case of a passive business
asset that suffered no wear and tear, a taxpayer would have to
prove a determinable useful life. An example of a passive
business asset that normally would suffer no wear and tear is a
painting displayed for business purposes. E.g., Clinger v.
Commissioner, T.C. Memo. 1990-459 (painting purchased by a
professional artist and displayed in part for marketing reasons
not recovery property for failure to prove determinable useful
life). Once a taxpayer establishes that an asset is subject to
exhaustion, wear and tear, or obsolescence, however, we need not
concern ourselves with the particular useful life of the asset.
Liddle v. Commissioner, 103 T.C. at 296-297; Simon v.
Commissioner, supra. It is of course possible that the exotic
automobiles might some day become museum pieces. Respondent
suggests that they were museum pieces, but she offers no evidence
to support that claim. We are satisfied that the exotic
automobiles were show cars, which, because of obsolescence, had a
limited useful life, not museum pieces with an indeterminable
useful life. The facts of the Harrah's Club case are
distinguishable.
At the conclusion of the trial in this case, respondent
stated that she no longer would rely on section 183 as a basis
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