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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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