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Petitioners have stipulated that they have not provided any
information regarding the acquisition dates and costs of these
three vehicles. Petitioners have substantiated the $2,196 cost
basis of the Chevy C-50 and the $4,176 cost basis of the Dodge
3/4-ton. Accordingly, respondent has conceded the depreciation
claimed by petitioners with respect to these two vehicles.
Petitioners placed the following assets in service in 1991:
General
Depreciation Recovery
Property System Basis Period Method Deduction
2 horses 3-yr. prop. $3,100 3 200 DB $1,033
Computer &
peripherals 5-yr. prop. 2,2265 200 DB 452
Office
furniture 7-yr. prop. 2107 200 DB 30
Business
library 20 yr. prop. 562 20 150 DB 21
Total 1,536
Petitioners have substantiated the claimed costs of these assets.
Accordingly, respondent has conceded the depreciation claimed by
petitioners with respect to these assets.
Petitioners have conceded that they erroneously computed a
portion of their claimed depreciation in 1991. As a result of
these errors, petitioners conceded $1,800 of the $14,510 total
depreciation claimed for the 1991 taxable year. On the basis of
petitioners' concession in the amount of $1,800, and respondent's
concession in the amount of $2,810, the remaining amount of
claimed depreciation in dispute is $9,900. See supra note 4.
With respect to the amount remaining in dispute, respondent
argues that petitioners' failure to substantiate the depreciable
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