Linda Klyce - Page 28




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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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