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years as an indication that petitioner lacked either a clear idea
of the work to be done or a determination to do it as soon as
practicable.
Petitioner’s tax return for TYE 8/31/92 shows that $130,523
was incurred in that year to acquire numerous items of
depreciable property ranging in cost from a few hundred to a few
thousand dollars. The property consists of lighting, sound
system, video vender booths, and the like, for the most part
equipment that would have been used for normal business
operations. Virtually all the items were classified as 7-year
property for ACRS purposes. During the 7-year history of its
business operations, in only one other year, TYE 8/31/88, had
petitioner made comparable expenditures on equipment. Some of
the purchases seem to represent normal replacement; some may
represent expansion of capacity concomitant with the remodeling
work that occurred in the same year. The nature of the items and
the circumstances of their acquisition suggest that the
expenditures could reasonably have been anticipated as of the end
of TYE 8/31/90 and TYE 8/31/91. But nothing in the record
confirms that large-scale equipment replacement and expansion of
capacity were in fact contemplated at these times. The evidence
is equally consistent with the inference that, for most of the
items, the purchase decision was made during TYE 8/31/92. Even
if petitioner’s management did plan the acquisitions prior to TYE
8/31/92, the total cost was not so large in relation to
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