112 T.C. No. 11 UNITED STATES TAX COURT DENNIS L. HAYDEN AND SHARON E. HAYDEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 590-98. Filed March 19, 1999. Ps are the sole partners in L. During 1994, L expended $26,650 on sec. 179 property and elected to expense $17,500 of that amount. Without regard to this deduction, L had no taxable income for the 1994 taxable year. The deduction under sec. 179 flowed through to Ps' 1994 return. Sec. 1.179-2(c)(2), Income Tax Regs., provides that a "partnership may not allocate to its partners as a sec. 179 expense deduction for any taxable year more than the partnership's taxable income limitation for that taxable year". Ps contend that the regulation is invalid. Held: Sec. 1.179-2(c)(2), Income Tax Regs., is valid and respondent's disallowance of the deduction is sustained. Dennis L. Hayden and Sharon E. Hayden, pro se. Brian M. Harrington, for respondent. OPINION DAWSON, Judge: This case was assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(3) andPage: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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