- 21 - conclude, therefore, that petitioner is not entitled to deductions for partnership losses in 1985, 1986, or 1987. Investment Income Credit Petitioner claimed a $1,000 investment tax credit on his 1985 tax return for the Chrysler. Respondent disallowed the credit. Respondent argues that the Chrysler was not a "qualified investment"; petitioner contends that it was. In 1985, sections 38(a) and 46(a) allowed an investment tax credit to a taxpayer making a "qualified investment". A "qualified investment" must be section 38 property. Sec. 46(c). Section 38 property is limited to certain property with respect to which depreciation or amortization is allowable. Sec. 48(a); sec. 1.48-1(a), Income Tax Regs. As observed above, petitioner is not entitled to depreciate the Chrysler. Moreover, because petitioner has not adduced, and we are not aware of, any authority providing that the expenditure at issue is amortizable, we conclude it is not. See Mann v. Commissioner, T.C. Memo. 1993-201. Accordingly, we conclude that petitioner is not entitled to an investment tax credit in 1985. Dependency Exemption On his 1986 tax return, petitioner claimed a dependency exemption for Anupam. Respondent disallowed the exemption. Respondent argues that petitioner did not prove that he providedPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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