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affd. 893 F.2d 656 (4th Cir. 1990).
The record establishes that petitioners used the estimated
replacement cost for the computer simulator in determining the
respective depreciation deductions claimed with respect to that
simulator in petitioners’ 1997 return and petitioners’ 1998
return. The record also establishes that petitioners took a
deduction for Mr. Horwath’s 1998 travel expenses in petitioners’
1998 return even though Mr. Horwath was entitled to a reimburse-
ment by TGC for such expenses, which he chose not to claim.
With respect to the respective depreciation deductions
relating to the computer simulator that petitioners claimed in
petitioners’ 1997 return and petitioners’ 1998 return, assuming
arguendo that petitioners were not negligent in claiming that
they, as the stockholders of TGC, were entitled to such deprecia-
tion deductions, the basis that they claimed in Form 4562 relat-
ing to Mr. Horwath’s 1997 Schedule C in determining those depre-
ciation deductions, namely, the estimated replacement cost of
that computer simulator, has no support in the Code, the regula-
tions, or the caselaw. See secs. 167(c), 1011, 1012; secs.
1.167(a)-1(a), 1.1011-1, 1.1012-1(a), Income Tax Regs.; Meredith
Corp. & Subs. v. Commissioner, 102 T.C. 406, 423 (1994); Dumont-
Airplane & Marine Instruments, Inc. v. Commissioner, 28 T.C. 1308
(1957).
With respect to the deduction for Mr. Horwath’s 1998 travel
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