- 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,Page: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 Next
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