- 25 - 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)Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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