Wilburn C. Hall, Jr. - Page 59

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        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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