Mary K. Fisher and Charles F. Patterson, et al. - Page 12

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          additional depreciation in the amount of $374 for the taxable               
          year 1992, attributable to a computer and peripherals listed on             
          the 1991 return with a basis of $5,405, but for which no                    
          depreciation had been claimed for the 1992 taxable year.                    
               Petitioners have established the bases of assets that were             
          placed in service in 1991.  Respondent, therefore, concedes that            
          petitioners are entitled to depreciation with respect to those              
          assets in the amount of $2,180 for the taxable year 1992.                   
               Petitioners claimed depreciation for the 1992 taxable year             
          with respect to six vehicles in the following amounts:                      
                    Business   Placed in  Cost   Remaining                            
          Description      Use     Service   Basis    Basis    Years Method  Deduction
          Dodge 1-Ton    100% 1/1/88   $2,500    $432  5   100 DB     $173            
          Jeep Wagon    100   1/1/88    1,200     208       5   200 DB       83       
          Ford 1-Ton    100   1/1/88    2,000     346       5   200 DB      138       
          Chevy- C-50    100        8/6/91    2,196   1,756       5   � 200 DB    702 
          Dodge 3/4-Ton  100        8/10/91   4,176   3,340       5   � 200 DB  1,336 
          Ford F-350     100  2/15/92   6,010   6,010       5   � 200 DB  1,202       
               Total                                        3,634                     
          The first five vehicles listed are the same five vehicles upon              
          which petitioners claimed depreciation in 1991.  The facts                  
          pertaining to petitioners' calculation of the depreciable bases             
          of these five vehicles and petitioners' substantiation of their             
          costs and acquisition dates are the same as those facts                     
          applicable to the 1991 taxable year.  Accordingly, respondent has           
          conceded that petitioners are entitled to depreciation relating             
          to the Chevy C-50 and Dodge 3/4-ton in the amounts of $702 and              
          $1,336, respectively.  Petitioners' claimed depreciation with               
          respect to the three vehicles placed in service on January 1,               




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