- 5 - deeper than the first rig.4 Petitioner also purchased diesel and electric welding equipment for $3,500. Later during the year, petitioner purchased "Inner Kelly" equipment for use with the recently purchased rig, at a cost of $30,962. Although the second drill rig was in working order when purchased by petitioner, he spent substantial time and money renovating it, and keeping it in working order. From the end of May 1985, through the beginning of July 1987, petitioner had no employment other than his drilling operation, and devoted the bulk of his waking hours working on the drill rig and looking for jobs on which he could use it. Notwithstanding that petitioner engaged in wage-earning employment after July 1987 for various employers (see infra p.7), he continued to spend substantial time on activities under the name "De Boer Drilling Co." Petitioner spent approximately 80 percent of this time working on the drill rig and 20 percent looking for drilling jobs. For the purchase price and capital costs of work done on the second drill rig from 1985 through 1989, petitioner claimed cost recovery deductions of approximately $88,000. Petitioner also claimed expense deductions for De Boer Drilling Co. of approximately $113,000 during 1985 through 1991. During this 4The second drill rig is a Hughes Tool Co. Model TAP-120T, also approximately 12 feet wide and 70 feet long, and weighing approximately 150,000 pounds. This rig is capable of drilling holes from 18 inches in diameter to 120 inches in diameter and can dig efficiently to a depth of 120 feet.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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