- 35 - (2) Petitioner expended $4,471.12 for office improvements during 1987 (Ex. 38-R, lines 222-228). (3) Petitioner purchased a copier for $3,068.64 during 1987 (Ex. 38-R, lines 323-332). (4) Petitioner purchased computer furniture for $3,003.09 during 1987 (Ex. 38-R, lines 212-218). (5) Petitioner purchased office furniture and computer- related items during 1988 totaling at least $5,632.26.16 Respondent has conceded that petitioner expended the above- listed amounts and that petitioner may depreciate these items but attempts to reconfigure petitioner’s deduction by offering a different depreciation alternative (7-year depreciation). We reject respondent’s attempt to recalculate petitioner’s depreciation and section 179 expense deduction because respondent, who raised this issue for the first time in a supplemental status report filed after trial, had the burden of producing evidence regarding the proposed recalculation and 15(...continued) the summary exhibits, Exhibits 38-R through 41-R, will assist the parties in understanding which items we are allowing petitioner to deduct and in preparing the Rule 155 computations. 16Our inability to account for the full cost of items purchased during 1988 and included in the sec. 179 expense deduction claimed by petitioner is attributable to the fact that petitioner’s depreciation and sec. 179 records were unbundled during the pretrial review of petitioner’s records and mixed in with petitioner’s office supplies records. We have no doubt, however, that petitioner expended the amounts claimed for 1988 (Ex. 39-R, lines 228-238, 241, 243-246, 248-259).Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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