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bases in, or acquisition dates of, the assets in question
precludes their claims for depreciation.
(2) 1992
On Schedule C of their 1992 tax return, petitioners claimed
the following depreciation:
Assets placed in service before 1991 $4,340
Vehicle 3,634
Assets placed in service in 1991 202
Total depreciation 18,176
1 Petitioners' return, as well as the stipulation of facts,
incorrectly calculated this total as $8,166.
The claimed depreciation attributable to assets placed in service
before 1992 is as follows:
Placed in
Property Years Percentage Basis Service Deduction
3 horses (now 2) 366.67 $1,954 1/1/90 $434
2 horses 3 66.67 3,100 1/1/91 1,378
Business equipment 5 40.00 3,895 1/1/88 269
Machinery/equipment 5 40.00 12,693 1/1/88 877
Farm tools 540.00 479 1/1/89 53
Business equipment 5 40.00 643 1/1/90 123
Computer & peripherals 540.00 2,226 1/1/91 710
Office furniture 7 28.57 1,200 1/1/88 107
Office furniture 7 28.57 210 1/1/91 51
Professional library20 7.50 4,125 1/1/88 236
Professional library20 7.50 526 1/1/89 33
Professional library20 7.50 265 1/1/90 18
Professional library20 7.50 562 1/1/91 41
Total 4,330
With respect to those assets placed in service before 1992, the
facts pertaining to petitioner Charles F. Patterson's calculation
of depreciable bases and petitioners' substantiation of costs and
acquisition dates are the same as those facts applicable to the
1991 taxable year, discussed supra. Petitioners now claim
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