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1.179-5(b), Income Tax Regs. Moreover, the taxpayer shall
maintain records that permit specific identification of each
piece of section 179 property and that reflect how and from whom
such property was acquired and when such property was placed in
service. See sec. 1.179-4(a), Income Tax Regs. The expense
deduction under section 179(a) for any tax year "shall not exceed
the aggregate amount of taxable income of the taxpayer for such
taxable year which is derived from the active conduct by the
taxpayer of any trade or business during such taxable year";
however, any amount disallowed may be carried forward to later
taxable years. See sec. 179(b)(3)(A) and (B).
Petitioner submitted photocopies of various invoices and
receipts to support her contention that Special O placed in
service during 1993 a word processor, an awning with lettering, a
computer, a laser printer, and two telephones, having a total
cost of $7,656.99.
After examining the submitted invoices and receipts, the
Court is not satisfied that Special O purchased the subject
property in the claimed amounts during 1993. Moreover, for any
property that the Court is satisfied was purchased during 1993,
the Court is not convinced that such property was purchased by,
or on behalf of, Special O in connection with the business of
Special O and was not used for personal purposes of the
shareholders. The evidence fails to satisfy the Court that, with
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