Gregory H. and Elizabeth A. Price - Page 14




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               On the partnership’s and on petitioners’ Federal income tax            
          returns for the years in issue, the costs of some of the videos             
          purchased for rental to customers were expensed currently.  In              
          the partnership's and on petitioners' income tax returns,                   
          depreciation expense deductions relating to the balance of the              
          videos rented to customers were claimed using the Modified                  
          Accelerated Cost Recovery System, a 3-year life, and the half-              
          year convention.                                                            
               On audit, respondent disallowed the current expenses claimed           
          for the cost of videos rented to customers.  Respondent also                
          determined that the proper method for computing depreciation on             
          the videos was the straight-line method using a 2-year life and a           
          $5 per-tape-salvage value (straight-line method).  For some                 
          years, respondent’s adjustments to depreciation resulted in a               
          decrease in the depreciation claimed, and in other years,                   
          respondent's adjustments to depreciation resulted in an increase            
          in the depreciation to be allowed.                                          
               The schedule below sets forth respondent’s recomputation of            
          the partnership’s and of petitioners' allowable depreciation                
          relating to videos rented to customers:                                     












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