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expense the cost of used file cabinets, chairs, and tables. Nor
is petitioner entitled to any depreciation allowance for such
property. Petitioner failed to prove (e.g., by producing a bill
of sale) that he acquired any such property; assuming that he
did, petitioner failed to prove (e.g., by producing a canceled
check or credit card receipt or statement) its cost.
Finally, we consider the depreciation deductions claimed by
petitioner on his Schedules C for 1999 and 2000 in the amounts of
$15,743 and $4,157, respectively. Here our analysis is hampered
by the fact that the record does not include a depreciation
schedule for either of the years in issue.14 Nevertheless, we
understand that depreciation was claimed principally in respect
of one or two automobiles and several pieces of computer
equipment.
As we understand it, petitioner claims depreciation on a
“brand new” 1999 Toyota Camry that he acquired in May 2000,
allegedly for $22,500.15 Although the record includes a “Bill of
Sale” dated May 2, 2000, there is a reference on petitioner’s
“Balance Sheet” for the calendar year 1999 to “Automobile--1999
14 Although the record includes a “Depreciation Worksheet”
for 1997, it would appear that the property listed therein would
have been fully depreciated before 1999.
15 The Texas Certificate of Title describes the Camry as
“rebuilt salvage” and as having 19,840 miles on the odometer at
the time that the title was transferred to petitioner.
At trial, petitioner testified that “I was offered $70,000”
for the car.
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