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Cohan v. Commissioner, supra; see also Finley v. Commissioner, 255
F.2d 128, 133 (10th Cir. 1958), affg. 27 T.C. 413, 425 (1956).
(1 ) Depreciation
As shown in table 7, supra, petitioner claims depreciation
deductions for a pickup truck, a house trailer, an airplane, and a
tractor and implements.
Petitioner used the 1981 Chevrolet pickup truck in his law
practice and Hall Farms. As we have pointed out, petitioner is not
permitted to deduct expenses of his corporations, but he is
permitted to deduct his expenses of the trades or businesses he
conducted directly--his law practice and Hall Farms. Petitioner
has not shown us what was the amount of his depreciable basis in
the pickup truck, nor how much of the use of the pickup truck was
for deductible business purposes, as distinguished from use for
the businesses of the Corporations and from use for petitioner's
personal purposes.
Yet, in 1982 the pickup truck was relatively new and
petitioner paid $1,087 interest on a loan to finance this truck.
From this we conclude, and we have found, that petitioner had a
depreciable basis in the pickup truck in 1982. Also, we have found
that petitioner used this pickup truck to some extent in his law
practice and Hall Farms activities.
Once we are convinced that there was some trade or business
use and that there was some depreciable basis, we are not free to
disallow all depreciation deductions merely because we cannot tell
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