- 59 -
how much is to be allowed. Doing the best we can-with the
record in the instant case and applying the principle of Cohan v.
Commissioner, 39 F.2d at 543-544, we hold (and we have found) that
petitioner is entitled to deduct for 1982 on Schedule C $200 of
the claimed $1,774 depreciation on his pickup truck. Gerling
International Insur. Co. v. Commissioner, 98 T.C. 640, 659 (1992),
and cases cited therein.
Petitioner used the house trailer and the 1979 Cessna 180
airplane in his drilling activities. We do not allow any
depreciation deduction for these items because we do not have any
information in the instant case's record from which we could
conclude (1) that petitioner used these items at all in his trades
or businesses, rather than in the trade or business of one of the
Corporations, or (2) that petitioner, rather than one of the
Corporations, owned the house trailer or the airplane.
Petitioner used the tractor and implements on the Akota
Ranch. We do not allow any depreciation deduction for these items
because we do not have any information in the instant case's
record from which we could conclude (1) that petitioner used these
items at all in his trades or businesses, or (2) that petitioner,
rather than one of the Corporations, owned the tractor and
implements. Nothing in the record connects the tractor and
implements, or Akota Ranch, with Hall Farms.
Petitioner has not claimed depreciation deductions, as such,
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