- 134 - 1974 and 1975 because he has not shown that it was an asset used in his trade or business or for the production of income. In 1978 petitioner provided Cadillacs to Mr. Dinunzio (his son-in-law), Mr. Dutton, and Clem and Priscilla Meier, each of whom was a CDC employee. Petitioner also had an automobile. He claimed depreciation on automobiles in the amounts of $9,311.30 in 1974, $8,280.80 in 1975, $7,339 in 1977, $13,865 in 1978, $12,000 in 1979, $12,000 in 1980, and $645 in 1981. In the notices of deficiency respondent allowed automobile depreciation of $4,072 in 1974 and $2,068 for each of the years 1978 through 1980. Petitioner presented no evidence with respect to the basis claimed for the various automobiles reflected on his depreciation schedules. He and the employees admitted that the automobiles were often used for personal purposes. Mr. Dinunzio, Mr. Dutton, and the Meiers sometimes used the automobiles provided by petitioner in their employment for CDC or its subsidiaries. Petitioner is not entitled to depreciation expenses on the automobiles in excess of the amounts allowed by respondent because he has not shown the extent to which the automobiles were used in his trade or business or his bases in the automobiles. Petitioner is not entitled to a loss of $2,716 claimed on the trade-in of automobiles for 1978.Page: Previous 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 Next
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