Lana Faye Green - Page 8

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               Computer       $1,842         Camera         $953                      
               Computer       4,014          Desk           450                       
               Copier         5,384          Typewriter     199                       
               Filing Cabinet    621         Neon           13,679                    
               Petitioner contends that she is entitled to section 179                
          expense deductions for these items because she timely filed her             
          original election under section 179.  She argues that she is                
          allowed to amend her original election and claim the maximum                
          deduction for 1994 in the amount of $17,500.  Respondent has not            
          consented to petitioner's revocation or change of the items or              
          costs claimed with her original election.                                   
               Section 179(a) generally allows a taxpayer to elect to treat           
          the cost of section 179 property as a current expense in the year           
          the property is placed in service, within certain dollar                    
          limitations.  See sec. 179(b).  The section 179 election must               
          specify the items of section 179 property to which the election             
          applies and the portion of the cost of each of such items which             
          is to be taken into account under section 179(a).  Sec.                     
          179(c)(1)(A); sec. 1.179-5(a)(1) and (2), Income Tax Regs.  The             
          election must be made on the taxpayer's first income tax return             
          for the taxable year or a timely filed amended return.  Sec.                
          179(c)(1)(B); sec. 1.179-5(a), Income Tax Regs.  An election made           
          on an amended return is valid only if such amended return is                
          "filed within the time prescribed by law (including extensions)             
          for filing the return for [the] taxable year".  Sec. 1.179-5(a),            
          Income Tax Regs.                                                            





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