JHK Enterprises, Inc., A California Corporation - Page 14




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          assets.  Sec. 165(b).  Respondent contends that petitioner has              
          failed to establish an adjusted basis other than zero for any of            
          the purportedly abandoned assets.  The only documentary evidence            
          petitioner provided to establish the amount of the claimed loss             
          deduction for abandonment of tangible assets is the equipment               
          schedule.  The equipment schedule lists the cost, but not the               
          adjusted basis, of each asset.                                              
               Respondent argues that several of the assets listed as                 
          abandoned on the equipment schedule were fully depreciated prior            
          to 1995, and, therefore, had an adjusted basis of zero in 1995.             
          For example, the equipment schedule lists as abandoned a                    
          televideo system with a cost in the amount of $25,700.  A                   
          depreciation schedule attached to petitioner’s 1994 Federal                 
          corporation income tax return indicates that a televideo system             
          with a cost of $25,700 was fully depreciated before 1994.                   
          Consequently, in 1995, this asset had an adjusted basis of zero.            
          Petitioner offered no explanation for why it should be allowed to           
          deduct the stated cost, rather than the adjusted basis, of any              
          purportedly abandoned asset.  We agree with respondent that                 
          petitioner has failed to establish an adjusted basis other than             
          zero for any of the purportedly abandoned assets.                           
               Petitioner has not demonstrated that it sustained a                    
          deductible loss pursuant to section 165(a) for the abandonment of           
          any tangible asset.                                                         






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