Carolyn Lamb - Page 9

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          any witnesses.  Perhaps some witnesses who could have provided              
          corroborating testimony could not be located.  But one would                
          think that those relatives whom petitioner identified at trial as           
          involved (at least on a volunteer basis) in her businesses could            
          have been called to support her case.  See Pollack v.                       
          Commissioner, 47 T.C. 92, 108 (1966), affd. 392 F.2d 409 (5th               
          Cir. 1968); Wichita Terminal Elevator Co. v. Commissioner, 6 T.C.           
          1158, 1165 (1946), affd. 162 F.2d 513 (10th Cir. 1947).                     
               With these preliminary comments in mind, we turn now to the            
          specific adjustments in issue, beginning with petitioner’s child            
          care business.                                                              
          A.  Child Care Business                                                     
               Petitioner claimed a deduction of $3,000 pursuant to section           
          179 for the purchase of a computer and printer in connection with           
          her child care business.  Respondent disallowed the deduction on            
          the ground that petitioner failed to establish her cost in the              
          equipment and the date the equipment was placed in service.                 
               Section 179(a) allows a taxpayer to treat the cost of                  
          certain property as a current expense for the year in which such            
          property is placed in service, within specified dollar                      
          limitations.  The taxpayer is required to maintain records that             
          permit specific identification of each piece of section 179                 
          property and that reflect how and from whom such property was               
          acquired and when it was placed in service.  Sec. 1.179-5(a),               






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