Floyd L. Garrett and Dorothy G. Garrett - Page 16

                                       - 16 -                                         

          Year      Corporation      Muscle Car Expense    Improper Deduction         
          1989      FGI                 $202,453            $243,682                  
                    TTI                 136,645             152,838                   
                    BEL                 --                  --                        
          1990      FGI                 257,604             291,930                   
                    TTI                 16,259              16,259                    
                    BEL                 --                  --                        
          1991      FGI                 2,123               10,615                    
                    TTI                 --                  --                        
                    BEL                  9,487              40,503                    
          Totals                        $624,571            $755,827                  

               Respondent agrees that these expenses relate to petitioners'           
          muscle car collection; however, she disagrees that the                      
          expenditures constitute deductible expenses.  Respondent argues             
          that petitioners have not established that these expenditures are           
          ordinary and necessary, as opposed to capital expenditures, and             
          that petitioners had not yet entered into a trade or business in            
          1989, 1990, or 1991; i.e., petitioners' activities were                     
          preparatory, at best, to future business activities.  We agree.             
               A taxpayer who is carrying on a trade or business may deduct           
          all the ordinary and necessary expenses paid or incurred in                 
          connection with the operation of the business.  Sec. 162(a).                
          However, an expense paid or incurred must be capitalized and may            
          not be deducted if it materially enhances the value, use, life              
          expectancy, strength, or capacity of the property.  Sec.                    
          1.263(a)-1(b), Income Tax Regs.  Petitioners have not proven that           
          the expenditures in question did not materially enhance the                 
          value, use, life expectancy, or strength of the muscle cars.                





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