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for Bradley. Petitioners used two other vehicles for their own
transportation.
The van was also used to transport Bradley to and from
school every day. The van was used because the school bus in the
town where they lived was not equipped with a wheelchair lift.
Petitioners wrote to the superintendent of schools to request
that the school district purchase a wheelchair lift for the
school bus, but the request was denied due to the low budget of
the small community.
Petitioners also used the van whenever they needed to take
Bradley on trips with them. Petitioners used the van for a trip
in 1994 to drive to Missouri for a family emergency. They
decided to take the van to Missouri in order to accommodate
Bradley’s medical condition at the time. The doctors advised
petitioners that Bradley, who was then in a full body cast, could
not travel by air. Petitioners also could not find a child care
person who was willing to care for a child in a body shell.
On the recommendation of their certified public accountant,
petitioners deducted the cost of the van and the conversions at a
rate of $5,500 per year for 1991, 1992, 1993, 1994, and 1995.
Respondent audited petitioners’ 1994 and 1995 tax returns and
denied petitioners’ depreciation deduction for both years.
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Last modified: May 25, 2011