- 55 - 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).Page: Previous 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 Next
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