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that the Neon was used in her law practice or any other specific
business which she actively conducted during 1994. Based on the
record, we conclude that the Neon does not constitute section 179
property with respect to petitioner. We hold that petitioner is
not entitled to a section 179 expense deduction for 1994 in
excess of the amount allowed by respondent.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011