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the income of the equipment was not forecasted in order to
calculate the depreciation deduction. Petitioner’s president
stated that revenue generated by the equipment dropped off after
the fourth or fifth quarter. Thus, under the income forecast
method of depreciation, petitioner would not have depreciated the
machines evenly over 2 years. We conclude that petitioner did
not use the income forecast method to depreciate its equipment,
but, rather, a term of 2 years.
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not herein
discussed, we find them to be irrelevant or without merit.
To reflect the foregoing,
An appropriate order
will be issued granting
respondent’s motion for
partial summary judgment.
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Last modified: May 25, 2011