- 32 - Thus, petitioners' experience indicates that the salvage value for their rental units was negligible--proceeds from the sales of rental units to third parties were for most rental units less than 3 percent of their original acquisition cost. In such circumstances, we conclude that petitioners were permitted to ignore such salvage value in determining the depreciation deduction for their property. Sec. 167(f) (before repeal in 1990 by the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101- 508, sec. 11812(a)(1) and (2), 104 Stat. 1388, 1388-534); sec. 1.167(f)-1, Income Tax Regs. In Bailey v. Commissioner, 90 T.C. 558, 620 (1988), affd. in part, vacated in part and remanded 912 F.2d 44 (2d Cir. 1990), we stated, in discussing the application of the income forecast method to the taxpayer's contractual rights to films: "During the years in issue, the values of these contract rights at the end of their anticipated useful lives were so negligible that salvage values need not be taken into account." Therefore, since petitioners' salvage values were negligible, it was proper, under these circumstances, for petitioners to depreciate the total cost of their rental units. Since the salvage value is inconsequential and since the parties stipulated that 1991 and 1992 data did not vary materially from 1987 and 1988 data, we hold that petitioners,Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011