William W. Halle IV, and Janice C. Halle - Page 25

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          contained no evidence that a shorter recovery period was more               
          appropriate, taxpayers failed to carry their burden of proof).              
          Therefore, we sustain respondent as to the $15.84 of allowed                
          depreciation.                                                               
               D.  Moving Expenses                                                    
               On his Schedule C, petitioner claimed moving expenses in the           
          amount of $1,254 attributable to his locksmith business assets.             
          Respondent disallowed the entire amount on the ground that the              
          expense was a contingent liability in 1990.                                 
               On January 10, 1991, petitioners paid North Park                       
          Transportation Co. $1,253.37 for shipment of the locksmith                  
          business assets from New Jersey to Wyoming.  The bill of lading,            
          dated December 21, 1990, issued by North American Van Lines shows           
          that payment in the amount of $3,349.98 was to be "C.O.D.".  Two            
          Consignee Memos, dated January 8, 1991, in the total amount of              
          $1,253.37, were issued by North Park Transportation Co.  Both               
          were presented to petitioners on January 10, 1991, stamped                  
          "Driver collect on Delivery".  Both bear the handwritten notation           
          "paid" and petitioners' check number.                                       
               Petitioner elected the accrual method of accounting for the            
          business.  Sec. 446.  Under this method, an expense is deductible           
          when all events have occurred to establish the fact of liability,           
          the amount can be determined with reasonable accuracy, and                  
          economic performance has occurred.  Sec. 461(h)(1), (4); United             
          States v. General Dynamics Corp., 481 U.S. 239, 243 (1987)                  




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