- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011