Mary K. Fisher and Charles F. Patterson, et al. - Page 7

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          section 195, and that petitioners had failed to adequately                  
          substantiate the claimed expenditures.                                      
          (c)  Depreciation                                                           
               (1) 1991                                                               
               On Schedules C of their respective tax returns for the                 
          taxable year 1991, petitioners claimed the following combined               
          depreciation:                                                               
               Assets placed in service before 1991         $11,044                   
               Vehicles                                     1,930                     
               Assets placed in service in 1991          1,536                        
                    Total depreciation                      14,510                    
          The claimed depreciation attributable to assets placed in service           
          before 1991 is as follows:                                                  
                                                  Placed in                           
          Property           Years Percentage Basis    Service    Deduction           
          20 horses           3    66.67    $77,000    1/1/88    $5,723               
          Business equipment  5    40.00     3,895    1/1/88       449                
          Computer & peripherals  540.00     5,405    1/1/88       669                
          Machinery & equipment  5 40.00     12,693    1/1/88     1,462               
          Nonlisted vehicles  5    40.00      7,600    1/1/88       876               
          Office furniture    7    28.57     1,200    1/1/88       150                
          Professional library20   7.50      4,125    1/1/88       272                
          3 horses            3    66.67     1,954    1/1/90     1,027                
          Farm tools              540.00     479    1/1/89       ---                  
          Business equipment  5    40.00     643    1/1/90       359                  
          Professional library20   7.50      526    1/1/89      ---                   
          Professional library20   7.50      265    1/1/90         57                 
               Total                                        11,044                    

               Petitioners owned 19 horses when they commenced operation of           
          Arabian Hill on January 1, 1988.  Petitioners had acquired 14 of            
          the 19 horses in question, and the remaining 5 were foaled at               
          Arabian Hill.  Petitioners calculated the depreciable bases of              






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