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1120S to treat $10,000 of the claimed $13,265 depreciable cost of
a 1995 Plymouth Neon (the Neon) as a section 179 expense.2
The Neon was purchased by petitioner in her own name in
September 1994 from Salem Chrysler-Plymouth, Inc. in Dayton,
Ohio. A State of Ohio memorandum certificate of title issued
September 30, 1994, lists petitioner as the owner of the Neon.
Petitioner did not transfer ownership of the Neon to Master Plan
prior to the end of 1994.
On September 29, 1997, nearly 2 weeks after the statutory
notice of deficiency was issued, respondent received an amended
return from petitioner for her 1994 taxable year. On the amended
return, she again claimed a Schedule C depreciation and section
179 expense deduction in the total amount of $14,624. However,
she attached to the amended return a single Form 4562 on which
she claimed depreciation and section 179 expense deductions in
the total amount of $16,304. She did not claim a section 179
expense deduction on the Schedule E attached to her amended
return. On self-prepared reports, similar to the reports
attached to her original return, petitioner claimed depreciation
deductions in the total amount of $4,091 and section 179 expense
deductions in the total amount of $12,213.
2 The total cost of the Neon was listed as $15,606. The
claimed depreciable cost in the amount of $13,265 took into
account only 85 percent of the total listed cost, since that is
the percentage for which the Neon was claimed to have been used
in Master Plan's business.
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