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$1,535. Accordingly, we hold for Mr. Ngo as to this issue.
7. Depreciation
Section 167(a) permits a depreciation deduction for the
exhaustion and wear and tear of property used in a trade or
business. Mr. Ngo claimed depreciation deductions of $12,245,
$8,746, and $3,124, respectively, during the years at issue.
Respondent disallowed all claimed depreciation expenses.
At trial, Mr. Ngo provided asset entry worksheets for the
years 1996 and 1997. Mr. Ngo has satisfied his burden, and his
claimed deductions are sustained for these years. However, Mr.
Ngo failed to provide any records for the basis of his claimed
depreciation expense deduction for 1995, and, therefore,
respondent’s determination is sustained for 1995.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decisions will be entered
under Rule 155.
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