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tion deductions at issue for 1993 other than Mr. Petty’s testi-
mony that “my Schedule C was filled out by my accountant, and I
stand by [that] as correct.”9
Based on our examination of the entire record before us, we
find that petitioners have failed to prove that they are entitled
for 1993 to deductions under section 167(a) for $4,150 of their
claimed Schedule C depreciation deductions that remain at issue
or any other amount in excess of that conceded by respondent.
At trial, petitioners raised a new issue with respect to the
purchase of a truck and a trailer, which they contend they
purchased in 1993. Although petitioners do not claim a specific
total dollar amount for any deductions with respect to that
purchase, it is our understanding that petitioners are claiming
depreciation on the truck and the trailer and all of the expenses
that they paid during their round trip from Alaska to Texas.10
Mr. Petty initially testified that the purchase price of the
truck and the trailer was approximately $40,000. He thereafter
testified that he did not remember the purchase price of the
9Assuming arguendo that petitioners had established that the
properties on which they are claiming the Schedule C depreciation
deductions at issue for 1993 were used in a trade or business or
held for the production of income during that year, we find on
the instant record that petitioners have failed to prove their
respective bases in any such properties for 1993.
10Mr. Petty indicated at trial that he wanted to claim “All
the expenses that went [sic] involved in the going to Texas, and
the truck and trailer in service in ‘93, whatever that is”.
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