Astrida Terauds - Page 10

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               At trial, petitioner did not dispute the amounts shown                 
          above.  She claimed that she should be allowed additional expense           
          deductions of $1,000 for depreciation for that portion of the               
          house that was rented, repairs, and expenses she incurred in                
          evicting the tenant.                                                        
               In the case of an individual, section 212 allows a deduction           
          for all the ordinary and necessary expenses paid or incurred                
          during the taxable year with respect to property held for the               
          production or collection of income and expenses for the                     
          management, conservation, or maintenance of property held for the           
          production of income.  Section 167(a)(2) allows as a depreciation           
          deduction a reasonable allowance for the exhaustion, wear and               
          tear, and obsolescence of property held for the production of               
          income.  Depreciation is designed to allow the taxpayer to secure           
          a return for the cost of the property.  United States v. Ludey,             
          274 U.S. 295, 300-301 (1927); Simon v. Commissioner, 103 T.C.               
          247, 253 (1994), affd. 68 F.3d 41 (2d Cir. 1995).  Generally, the           
          annual depreciation amount is a fraction or percentage of the               
          depreciable basis of the property computed in accordance with the           
          method of depreciation used.  Sec. 167(c)(1).                               
               Petitioner presented no evidence to establish the amounts              
          spent for repair of her rental property; she did not describe the           
          nature of the repairs and presented no receipts or other                    
          documentary evidence to corroborate her testimony.  Likewise,               

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