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tions in the notice of deficiency (notice) are erroneous. See
Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).
Depreciation Deductions for Aircraft Parts
In the notice issued to petitioners, respondent disallowed
the cost, inter alia, of the aircraft parts which Mr. Thomson
acquired during 1993 and 1994 and which petitioners claimed as
cost of goods sold in Schedule C for each of those years.
Respondent further determined in the notice that petitioners are
entitled to depreciation deductions for each year at issue with
respect to the aircraft parts that Mr. Thomson purchased during
each such year. Respondent calculated the depreciation deduc-
tions for certain of the aircraft parts in question over a 5-year
recovery period and for certain other such parts over a 7-year
recovery period. Respondent concedes on brief that all of the
aircraft parts in question are depreciable over a 5-year recovery
period.
Although not altogether clear, as we understand it, peti-
tioners are arguing for the first time on brief that the aircraft
parts2 that Mr. Thomson purchased during each of the years 1993
and 1994 are depreciable over a 3-year recovery period.3
2Petitioners do not dispute respondent’s determinations
regarding the books that Mr. Thomson purchased and used in
Aviation’s business activities.
3Petitioners contended at trial that for each year at issue
they are entitled to deduct as abandonment losses under sec.
165(a) the total amounts that Mr. Thomson spent during each such
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