Mary K. Fisher and Charles F. Patterson, et al. - Page 9

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          total of $54 to the cost bases of the horses, purportedly                   
          attributable to direct charges associated with their purchase.              
          Accordingly, petitioners claimed depreciation with respect to               
          these horses, calculating a total depreciable basis in the amount           
          of $1,954.  Petitioners have stipulated that they have not                  
          supplied any substantiation as to the cost of these three horses.           
               Petitioners claimed depreciation with respect to farm-                 
          related tools and equipment placed in service on January 1, 1989,           
          and business equipment placed in service on January 1, 1990.                
          Petitioners have stipulated that they have not provided any                 
          substantiation as to the cost of these items.                               
               Petitioners claimed depreciation with respect to library               
          materials placed in service on January 1, 1989 and 1990.                    
          Petitioners have stipulated that they have not provided any                 
          substantiation as to the cost of these items.                               
               Petitioners claimed depreciation with respect to the                   
          following five vehicles:                                                    
                    Business   Placed in  Cost   Remaining                            
          Description    Use  Service   Basis    Basis    Years  Method  Deduction    
          Dodge 1-ton    100% 1/1/88   $2,500    $720  5    200 DB     $288           
          Jeep Wagon    100   1/1/88    1,200     346       5    200 DB      138      
          Ford 1-Ton    100   1/1/88    2,000    576       5    200 DB      230       
          Chevy C-50    100       8/6/91    2,196   2,196       5    � 200 DB    440  
          Dodge 3/4-ton  100  8/10/91   4,176   4,176       5    � 200 DB    834      
          Total                                        1,930                          
          Petitioner calculated the depreciable bases of the three vehicles           
          that were placed in service on January 1, 1988, from his estimate           
          of their respective fair market values as of that date.                     





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