- 2 - issue is by way of depreciation, as allowed in the notice of deficiency. 2. Held, further, Ps may not now elect to expense any sec. 179 property they placed in service in either 1995 or 1996, because the period for making valid sec. 179 elections for the years in issue has expired. Sec. 179(c), I.R.C. 1986. Michael A. McGrath and Frances Y. McGrath, pro sese. Emile L. Hebert III, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION CHABOT, Judge: Respondent determined deficiencies in individual income tax against petitioners as follows: Year Deficiency 1995 $28,590 1996 3,026 After concessions by both sides, the issues for decision1 are as follows: (1) Whether petitioners may deduct under section 1622 the costs they incurred in 1995 in making permanent 1 The following adjustments are computational, i.e., they depend on resolution of the issues for decision: (1) Earned income credit for 1996, and (2) itemized deductions for 1995 and 1996. 2 Unless indicated otherwise, all section and chapter references are to sections and chapters of the Internal Revenue Code of 1986 as in effect for the years in issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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