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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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