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Target showing a Sony CFD530 for $139.99. Petitioner testified
that the receipt represents the purchase of a Sony facsimile
machine. Petitioner also offered a receipt from Sonia Reyes, of
the law firm Crosby, Heafey, Roach & May, in downtown Los
Angeles, showing the purchase of a Hewlett Packard Laser Jet
Series II laser printer for $750, and two receipts from Superbyte
Inc., showing the purchase of two computers for $1,045 and
$1,550, respectively.
We find that petitioner substantiated the purchase of the
above items for the use in her consulting business. Accordingly,
petitioner is entitled to a depreciation deduction premised on
cost bases of $139.99 for the fax machine, of $750 for the
printer, and of $2,595 for the computers. All items are 5-year
property as defined under section 168(e)(3)(B) and are subject to
the midquarter convention under section 168(d)(3)(A).
Petitioner failed to provide any evidence for the claimed
repairs/maintenance deduction and other deduction. Petitioner’s
Schedule C itemizes the other expenses of $4,000 to include bank
charges of $600, educational seminars of $750, and telephone of
$2,650. However, petitioner is deemed to have conceded these
items because she failed to offer any evidence to support these
amounts. Rules 142(a), 149; Pearson v. Commissioner, T.C. Memo.
2000-160.
The last issue for decision is whether petitioner is liable
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