- 22 - 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 travelPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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