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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. Consequently, although the Mach Buster had not
been flown in an air race during any of the years at issue, it
could still be considered depreciable in the year in which it
became "ready and available" for flying in air races.
The record reflects that the Mach Buster airplane was not
ready and available for air racing until sometime after 1997.
Although it appears that construction of the aircraft was
completed in early 1997, a so-called "flutter analysis" was
conducted on the Mach Buster by a third party during most of the
remainder of 1997. A flutter analysis was described by
petitioner as "an examination of the basic aerodynamics of the
airplane and the structure as completed." The flutter analysis
determines how an airplane will "react to the airloads on it"
during flight; i.e., whether the aircraft components will fly
smoothly or "flutter so rapidly that they destroy themselves."
The flutter analysis findings were not published until February
1998.
Petitioner contends that, even though the flutter analysis
findings were not published until February 1998, he could have
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