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In the notice of deficiency, respondent disallowed $17,479
of the claimed deduction; however, prior to trial, respondent
conceded that petitioner was entitled to an additional $284
depreciation deduction in connection with the computer repair
tools. This reduced the depreciation/section 179 expense
deduction in dispute to $17,195.
Section 167(a) allows taxpayers a depreciation deduction for
the exhaustion and wear and tear of property used in a trade or
business or held for the production of income. Property becomes
depreciable at the time it is placed in service. Piggly Wiggly
S., Inc., v. Commissioner, 84 T.C. 739, 745 (1985), affd. on
another issue 803 F.2d 1572 (11th Cir. 1986); Clemente v.
Commissioner, T.C. Memo. 1985-367; sec. 1.167(a)-10(b), Income
Tax Regs. Property is considered placed in service when it is
ready and available for a specifically assigned function. Piggly
Wiggly S., Inc., v. Commissioner, supra; Williams v.
Commissioner, T.C. Memo. 1987-308; sec. 1.167(a)-11(e)(1)(i),
Income Tax Regs.
Section 179 allows a taxpayer to elect to treat the cost of
section 179 property as a current expense in the year such
property is placed in service, within certain dollar limitations.
Sec. 179(a). An election under section 179 must be made on the
taxpayer's original return for the taxable year or an amended
return filed timely. Sec. 179(c)(1)(B); sec. 1.179-5(a), Income
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