Carolyn Lamb - Page 12

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          document that petitioner introduced to support her testimony was            
          a product registration card from Exmark Manufacturing Co., Inc.,            
          indicating that petitioner bought a 32-inch mower on May 20,                
          1995.  This document hardly supports a section 179 expense                  
          deduction for 2000.  In addition, petitioner’s returns for 1998             
          and 1999 report the purchase of lawn mowers in the aggregate                
          amount of exactly $16,000.  We are not persuaded that petitioner            
          spent yet another $5,500 on a lawn mower in 2000.                           
               Although petitioner certainly used a lawn mower(s) in her              
          business, there is nothing in the record to demonstrate                     
          persuasively that petitioner is entitled to a section 179 expense           
          deduction for the purchase of a $5,500 lawn mower in 2000.                  
                    c.  Conclusion                                                    
               In sum, petitioner did not satisfy her burden of proof as to           
          either section 179 expense deduction.  We therefore hold for                
          respondent on the section 179 issue as to both the trailer and              
          the lawn mower.                                                             
               2.  Depreciation Deductions                                            
               Petitioner claimed depreciation in the amount of $2,950 on a           
          Ford F150 truck and depreciation in the amount of $5,000 on a GMC           
          Suburban.  Respondent allowed in full the depreciation deduction            
          on the Ford; however, respondent disallowed the depreciation                
          deduction on the Suburban in its entirety on the grounds that               
          petitioner failed to establish ownership of the vehicle, its                






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