Stanley P. Zurn - Page 27

               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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