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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
1989.
To reflect the foregoing and concessions of the parties,
Decision will be entered under
Rule 155.
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Last modified: May 25, 2011