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the year that the property is placed in service. The allowance
is limited to $10,000, reduced (but not below zero) by the amount
by which the cost of the section 179 property placed in service
exceeds $200,000. See section 179(b). Thus, the allowance is
zero if the cost of the section 179 property exceeds $210,000.
Because petitioner purchased the King Air in 1991 for $225,000,
no section 179 allowance is available.10
3. Parts and Repairs
For taxable year 1989, petitioner seeks deductions totaling
$941 for unagreed expenses allegedly incurred for various parts
and repairs required for his aircraft. Respondent generally
contends that petitioner has failed to substantiate the business
purpose for each expenditure.11
On the basis of our review of the documentary evidence in
the record, we find that petitioner has adequately substantiated
an expenditure of $808 for an aircraft part. He has failed,
however, adequately to substantiate business purpose for the
remaining unagreed expenses at issue, which include numerous
small payments allegedly made to auto parts stores, a hardware
10 It also appears that petitioner made no proper election
for the sec. 179 allowance. See sec. 179(c). Given our holding
that petitioner is not entitled to any sec. 179 allowance,
however, we need not address this issue.
11 Respondent does not contend that any of petitioner’s
alleged expenditures for parts should have been capitalized under
sec. 263. Accordingly, we do not reach this issue.
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