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O in an amount greater than that allowed by respondent. For
1993, Special O claimed a section 179 expense deduction of
$10,570 for computers and related equipment. In the RAR for
Special O, respondent disallowed this deduction, in part, due to
lack of documentation to substantiate the cost of computer and
other such equipment.13 Respondent determined that Special O
failed to substantiate entitlement to any additional section 179
expense deduction for 1993. Alternatively, respondent contends
that Special O is not entitled to any additional section 179
expense deduction for 1993 under section 179(b)(3)(A) because
Special O's taxable income for 1993 did not exceed the section
179 amount that was allowed.
Section 179 allows a taxpayer to elect to treat the cost of
section 179 property as a current expense in the year such
property is placed in service, within certain dollar limitations.
See sec. 179(a). An election under section 179 must be made on
the taxpayer's original return for the taxable year or an amended
return filed timely. See sec. 179(c)(1)(B); sec. 1.179-5(a),
Income Tax Regs. Once made, this election may not be revoked
"except with the consent of the Secretary." Sec. 179(c)(2); sec.
13
In the notice of deficiency, respondent allowed petitioner a
$211 expense deduction under sec. 179 in connection with Special
O for 1993. The record does not reflect the specific property
for which this deduction was allowed, nor does the record reflect
respondent's reasons for allowing the deduction.
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