David A. and Paula J. Henderson - Page 6

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               We conclude that petitioners are not entitled to deduct                
          depreciation as a medical expense deduction under section 213 in            
          either 1994 or 1995.                                                        
               To reflect the foregoing and the concessions of the parties,           
                                                  Decision will be entered            
                                             under Rule 155.                          

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