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Respondent determined deficiencies in petitioner's Federal
income taxes for 1993 and 1994 in the amounts of $765.33 and
$8,499, respectively.
After concessions by the parties, the issue remaining for
decision is whether petitioner is entitled to a section 179
expense deduction for 1994 in excess of the amount allowed by
respondent.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner resided in Trotwood, Ohio,
on the date the petition was filed in this case.
Petitioner has worked as a self-employed attorney during and
since the taxable years in issue. As of the end of 1994, she was
also the majority shareholder of Master Plan Supplies, Inc.
(Master Plan), which was incorporated under the laws of the State
of Ohio on November 9, 1994. The parties have stipulated that
Master Plan properly elected to be treated as an S corporation
for its 1994 taxable year.
On a Schedule C attached to her 1994 return, petitioner
claimed a "depreciation and section 179 expense deduction" in the
amount of $14,624 as an expense of her law practice. On a
Schedule E attached to her 1994 return, petitioner claimed a
"section 179 expense deduction" in the amount of $9,000 in
connection with her interest in Master Plan. In support of the
claimed deductions, petitioner attached to her return two Forms
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