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property that had appreciated in value without any affirmative
act by the taxpayer, we held that expenses incurred by the
taxpayer were not expenses incurred for the management,
conservation, or maintenance of property held for the production
of income.
The case at hand is distinguishable from Ray. We believe
that petitioner's actions have caused his drill rig to appreciate
in value. A major purpose of petitioner in continuing to expend
the time, money, and effort on maintaining the drill rig in 1991
was to enhance the likelihood of obtaining a return on his
investment if and when he should subsequently sell the drill rig.
We hold that all expenses listed on Schedule C, for the tax year
1991, which we find were attributable to the management,
conservation, or maintenance of petitioner's drill rig, to be
properly deductible under section 212.
Under section 67, in the case of an individual, the
miscellaneous itemized deductions for any taxable year are
allowed only to the extent that the aggregate of such deductions
exceeds 2 percent of adjusted gross income. Section 1.67-
1T(a)(1)(ii), Temporary Income Tax Regs., 53 Fed. Reg. 9875 (Mar.
28, 1988) provides the deduction under section 67 includes
expenses for the production or collection of income for which a
deduction is otherwise allowable under section 212(1) or (2).
Thus, petitioner's allowable deduction for 1991 is subject to the
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