116 T.C. No. 17
UNITED STATES TAX COURT
SAM H. PATTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16428-99. Filed April 13, 2001.
For 1995, P elected, under sec. 179, I.R.C., to
expense a depreciable asset. R examined P’s 1995
Federal income tax return and reclassified as
depreciable three assets that P had originally
classified as “materials and supplies”. Following R’s
reclassification, P sought R’s consent to expense the
three reclassified assets under sec. 179, I.R.C. P was
unable to revoke (modify or change) his election
without R’s consent. R refused to give P consent to
revoke (modify) his original election.
Held: R’s refusal to consent, considering the
facts in this case, was not an abuse of discretion.
Hugh T. Echols, Sr., for petitioner.
Gordon P. Sanz, for respondent.
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