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In addition, petitioner argued and we have found that as of
the end of 1988 Cities was inactive with no hope of being
revitalized, and the road construction equipment was not being
used for business purposes. Petitioner contended that the debt
was worthless and that he had abandoned the road construction
equipment. In this regard, although petitioner did not specify
when inquiries about the road construction equipment were made,
he claims to have abandoned the road construction equipment,
ostensibly because it could not be located or because storage and
maintenance fees exceeded the value of the equipment.
Accordingly, we find that petitioner is entitled to the
depreciation claimed through the 1988 taxable year, but no
depreciation is allowable for the 1989 taxable year. Petitioner
is also entitled to a capital loss with respect to his $52,000
interest in the joint venture as of the end of 1988. Petitioner,
however, has not shown his entitlement to an abandonment loss of
the leased equipment due to his failure to isolate or specify the
time of such abandonment.
Issue 4. Whether Petitioner Overstated His Alimony Deduction by
$11,988 in Each Year 1985 Through 1989
Petitioner and his former wife Valery Zurn (Ms. Zurn) were
married in 1967 and divorced on August 2, 1978. Petitioner was
ordered in the divorce decree to pay Ms. Zurn alimony of $1 per
month for 15 years and $50 per month for child support, beginning
August 1, 1978. When petitioner originally received the divorce
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