Mary K. Fisher and Charles F. Patterson, et al. - Page 13

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          1988, remains in dispute.  In addition, petitioner placed in                
          service a Ford F-350 during the 1992 taxable year.  Petitioners             
          have substantiated the $6,010 cost basis of this vehicle, and               
          accordingly, respondent has conceded that petitioners are                   
          entitled to depreciation with respect to that vehicle in the                
          amount of $1,202.                                                           
               Petitioners now contend that they used additional nonlisted            
          vehicles in the operation of Arabian Hill, included on their 1991           
          returns with a basis of $7,600, for which no depreciation was               
          claimed on their 1992 return.  Petitioners now claim additional             
          depreciation in the amount of $525 with respect to these                    
          vehicles.                                                                   
               Petitioners placed the following assets in service during              
          1992:                                                                       
          General                                                                     
                   Depreciation             Recovery                                 
          Property              System       Basis    Period  Method  Deduction       
                                                                                     
          Machinery/equipment      5-yr. prop.     $543         5200 DB    $109            
          Computer &                                                                  
          peripherals              5-yr. prop.      3155         200 DB    63              
          Office furniture        7-yr. prop.      1257         200 DB      18            
          Business library        20-yr. prop.      31120     150 DB      12               
               Total                                        202                       

          Petitioners have substantiated their bases in these assets.                 
          Accordingly, respondent has conceded that petitioners are                   
          entitled to claimed depreciation in the amount of $202.                     
               On the basis of petitioners' concession in the amount of               
          $155, petitioners' claim for additional depreciation in the                 
          amount of $899 ($374 for computer peripherals plus $525 for                 



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