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that extent, therefore, and since the automobile was used
exclusively in the trade or business activity, petitioners have
satisfied the substantiation requirements of section 274(d) and
the requirements of section 280F to allow them a depreciation
recovery deduction under sections 167 and 168(a). Petitioners,
therefore, are sustained to the extent of a depreciation
allowance for the automobile.
As to the other disallowed Schedule C expenses, petitioners
presented no evidence to substantiate those expenses.
Respondent, therefore, is sustained on those items.
To account for the allowed depreciation,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011