Haralampos Katerelos and Irene Katerelos - Page 55

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            deductions under section 162(a) for automobile expenses for any                               
            of the years at issue.42  We therefore sustain respondent's                                   
            determinations disallowing those deductions for 1987, 1989, 1990,                             
            and 1991 and reject petitioners' contention that they are enti-                               
            tled to any such deduction for 1988.                                                          
                  Depreciation                                                                            
                  Petitioners claimed depreciation deductions in their returns                            
            for each of the years at issue with respect to properties that                                
            they claim they placed in service for their business, NDV, during                             
            1986 and that they claim had total bases of $76,052.  Respondent                              
            determined in the notice that petitioners are not entitled to                                 
            those depreciation deductions because they failed to establish                                
            (1) their bases in the properties with respect to which the                                   
            depreciation deductions were claimed and (2) that the properties                              
            with respect to which those deductions were claimed were depre-                               
            ciable assets.  On brief, respondent argues that petitioners                                  
            failed to establish what properties they placed in service during                             
            1986 and their adjusted bases in any properties they did in fact                              
            place in service during that year.  Petitioners bear the burden                               
            of proof on this issue.                                                                       
                  Section 167(a) allows a deduction for a reasonable allowance                            
            for the exhaustion, wear and tear of property used, inter alia,                               


            42  We note that petitioners also failed to prove that they                                   
            satisfy the requirements imposed by sec. 274(d)(4).                                           




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