Walter Raymond Wilkerson and Susan Gee Wilkerson - Page 7

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          of the check is written the explanation "Deposit for 37 cows".              
          Although petitioners alleged ownership of depreciable livestock,            
          they have not shown such livestock was acquired.  In addition,              
          petitioner, who is an accountant, did not provide any                       
          depreciation schedule or other records which would show the cost,           
          depreciation claimed, and basis remaining of the assets.                    
          Petitioners have also failed to show that the animals were held             
          for breeding or dairy purposes so as to be eligible for                     
          depreciation.  See, e.g., Rudolph Inv. Corp. v. Commissioner,               
          T.C. Memo. 1972-129.  We accordingly hold that petitioners have             
          not shown their entitlement to depreciation of cattle for 1988 or           
               To reflect the foregoing and concessions of the parties,               

                                             Decision will be entered under           
                                        Rule 155.                                     

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