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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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