Lana Faye Green - Page 7

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                              Description  Business Use  Elected Section              
               Activity          of Property   Cost/Basis    179 Expense              
          Sch. C R.N./Attorney     Computers      $1,842         $1,842               
          Sch. C R.N./Attorney     Computer       4,014          4,000                
          Sch. C R.N./Attorney     Copier         5,384          5,000                
          Sch. C R.N./Attorney     Filing cabinet    621         621                  
          Sch. C R.N./Attorney     Camera         572            500                  
          Sch. C R.N./Attorney     Desk           450            250                  
          From K-1's                                                                  
               Totals                        $12,883        $12,213                   
               Petitioner made no claim on the amended return for a section           
          179 expense deduction with respect to the Neon, either as a                 
          Schedule C expense of her law practice or as a Schedule E pass-             
          through item of Master Plan.  In her pretrial memorandum,                   
          petitioner listed as one of the issues to be decided in this                
          case:  "Whether the petitioner is entitled to claim depreciation            
          and Section 179 election for various items including a 1995 Neon            
          automobile and what is the correct amount of the deduction."  She           
          failed, however, to further address the issue in the pretrial               
          memorandum.  At trial, petitioner alleged that she filed a second           
          amended return on which she claimed the Neon as a section 179               
          expense deduction.  A copy of this second amended return was not            
          produced at trial.  Petitioner did not testify or otherwise                 
          introduce evidence of the extent, if any, that the Neon was used            
          in Master Plan's business or her law practice.  In her posttrial            
          memorandum, petitioner argues that she is entitled to section 179           
          expense deductions for 1994 for her costs of purchasing the                 
          following items:                                                            






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