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