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The stripping room (or more appropriately in petitioners'
case, the "stripping area") is located in the center of the
Tobacco Barn. It is 12 feet wide and 24 feet long. It consists
of plywood stacked to form a work bench, a small machine used to
strip tobacco, and a hydraulic press used to bale tobacco. The
stripping area is not always enclosed. Only in cold weather do
petitioners enclose the stripping area, using plastic sheeting
and plywood to provide shelter. It takes about a day to enclose
the stripping area.
The Tobacco Barn is generally not used in petitioners'
tobacco business between March and July. However, in some years,
a limited amount of tobacco may remain hanging in the Tobacco
Barn beyond February --for example when petitioners produce
tobacco in excess of their sales quota. Petitioners occasionally
use the Tobacco Barn to store farm equipment.
Petitioners own two other barns. These other barns are
referred to by petitioners as "combination barns". Combination
barns are of a sturdier design than the Tobacco Barn and may be
used to cure and process tobacco, as well as house cattle or
store grain.
On their 1994 Federal income tax return, petitioners
reported the cost of the Tobacco Barn as $16,730 and elected to
deduct $6,754 of that amount under section 179. Petitioners
claimed depreciation for the balance of the cost of the Tobacco
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