- 17 - C. Depreciation Section 167(a) allows "as a depreciation deduction a reasonable allowance for the exhaustion, wear and tear * * * of property used in the trade or business, or * * * of property held for the production of income." The depreciable basis of property acquired by purchase is cost. See sec. 167(g). If depreciable and nondepreciable property, such as improved real estate, is bought for a lump sum, the purchase price must be allocated between the land (nondepreciable property) and the depreciable improvements (e.g, buildings). See sec. 1.167(a)-5, Income Tax Regs. Depreciation deductions may not be claimed until an asset is placed in service. Rybak v. Commissioner, 91 T.C. 524, 561 (1988); sec. 1.167(a)-10(b), Income Tax Regs. On its 1985 return, Good Shepherd claimed a deduction for depreciation of $13,583, based on a total cost basis for depreciable property of $833,000. We assume that such depreciable property is a portion of the property. Deductions for depreciation as set forth in our findings of fact were claimed by Good Shepherd for 1986 through 1987. In our findings of fact, we have recited a description of the property as an improved 86-acre tract. Petitioners have proposed, although we have not found, that the purchase price paid by Good Shepherd for the property was over $1 million. Petitioners have failed to show on what basis Good Shepherd allocated the purchase price ofPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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