Susan E. Shores - Page 15

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          entitled to a deduction in the amount of $450 for telephone                 
          expenses.  Id.                                                              
               Petitioner did not claim any additional deduction for, or              
          present any other evidence to substantiate, expenditures for the            
          use of a home office.                                                       
               12.  Computer Cost                                                     
               Although not claimed on her Schedule C, petitioner contends            
          that the $2,200 cost of the computer she purchased is deductible            
          under section 179.  Petitioner offered a copy of her credit card            
          statement dated May 16, 1994, which indicates that she purchased            
          a computer for $2,200.  Petitioner testified that she used the              
          computer exclusively for her business with APIA.  On the basis of           
          this record, we find that petitioner purchased a computer for               
          $2,200 and used the computer solely for her activities with APIA.           
               Under section 179(a), a taxpayer may elect to treat the cost           
          of any section 179 property as an expense which is not chargeable           
          to capital account.  Taxpayers electing to do so may deduct the             
          cost of such property in the taxable year in which the property             
          is placed into service.  The aggregate cost which may be taken              
          into account under section 179(a) cannot exceed $17,500.  Sec.              
          179(b)(1).  Section 179(c)(1) provides that an election must:               
                    (A) 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 subsection (a), and                                              
                    (B) be made on the taxpayer's return of the tax                   





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