- 21 - Co. v. Commissioner, 359 F.2d 191, 198 (2d Cir. 1966), affg. in part, revg. in part, and remanding T.C. Memo. 1965-39; P. Dougherty Co. v. Commissioner, 159 F.2d 269 (4th Cir. 1946), affg. 5 T.C. 791 (1945). All five vehicles were available for use in petitioner’s business when he bought them. Petitioner placed each vehicle in service for depreciation purposes when he bought it. E. Whether Petitioners May Deduct More Depreciation for Business Property Than Respondent Allowed Petitioners contend that they may depreciate shop and office equipment in amounts greater than they claimed on their returns for the years in issue and greater than respondent allowed. Petitioners contend that respondent did not allow them to depreciate certain shop and office equipment that had useful lives and cost bases which had not been fully recovered as of the beginning of 1985. We disagree. Petitioners did not identify the equipment to which their contention applies or show that respondent had not already allowed a depreciation deduction for that equipment. F. Whether Petitioners May Deduct Net Operating Loss Carryforwards and Carrybacks and Use Investment Tax Credit Carryforwards Petitioners contend they may deduct net operating loss (NOL) carryforwards and carrybacks and use investment tax credit carryforwards. We disagree. Petitioners must prove the amount of the NOL carryforward or carryback deductions claimed and thatPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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