- 10 - do not meet the test for being similar in character to property for which the income forecast method of depreciation has been approved. Additionally, respondent contends in the notice of deficiency that in the event it is held that the assets on which petitioners have claimed the income forecast method of depreciation qualify for that method, a proper election has not been made under section 2.10 of Rev. Proc. 87-57, 1987-2 C.B. 687, and the method is not allowed. Respondent took the position in the judicial proceeding that: (1) The income forecast method of depreciation is not a valid method of depreciation to depreciate tangible personal property of the type utilized in petitioners’ rent-to-own businesses (i.e., furniture, appliances, televisions, stereo equipment, and video tape recorders); (2) petitioners failed to file elections pursuant to section 168(f)(1) to change their method of depreciation to the income forecast method for the assets placed in service for taxable years ending in 1987; (3) petitioners improperly applied the income forecast method when calculating depreciation deductions because petitioners failed to forecast the income to be received from the assets being depreciated and failed to make a reasonable adjustment for salvage value of the assets being depreciated. Thus, in the present case we need not consider two separate positions because there is no indication that respondent’s position changed or thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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