- 20 - consider in determining estimated useful life include exhaustion; wear and tear or decline from natural causes; obsolescence; economic changes; inventions; current developments in the industry and the taxpayer’s trade or business; climatic or other local conditions peculiar to the trade or business; and the taxpayer’s policy as to repairs, renewals, and replacements. Sec. 167; sec. 1.167(a)-1(b), Income Tax Regs. The taxpayer is responsible for establishing the reasonableness of the deduction for depreciation. Sec. 1.167(b)- 0(a), Income Tax Regs. Generally, depreciation deductions so claimed will be changed only where there is a clear and convincing basis for a change. Id. The parties disagree on the useful life of the garments and dust control items. Petitioner contends that it made a reasonable approximation of the useful life of its garments and dust control items based on its business practices and that there was no clear and convincing basis for a redetermination of the useful life by respondent. Petitioner approximated that the useful life of its garments and dust control items was less than 1 year or not substantially in excess of 1 year. The useful life determined by respondent was 4 to 10 years for mats, 4 to 10 years for mops, 1 to 4 years for towels, 2 to 4 years for industrial garments, and 4 to 10 years for clean room garments. Respondent primarily relies on an expert report andPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011