Christopher D. and Kristie M. Farran - Page 17
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expenses for tools if they are ordinary and necessary business
expenses. Sec. 162(a).
Petitioners have offered no documentation or testimony
regarding the $740.42 of tool expenses claimed beyond what
respondent allowed. We conclude that petitioners are not
entitled to deduct any additional amount for tools other than the
$90.58 agreed upon amount.
Petitioners claimed $115 for depreciation of tools Mr.
Farran used at his job. The cost of tools with useful lives
greater than a year is recoverable by depreciation. Secs.
167(a), 168(b); Seawright v. Commissioner, 117 T.C. 294, 305
(2001); Clemons v. Commissioner, T.C. Memo. 1979-273. Mr. Farran
testified that he did not have any receipts for the depreciated
tools but identified them as sockets and wrenches he thought
would last for years.
The only documentary evidence petitioners introduced to
support their claimed deduction was a depreciation schedule for
the tools that indicates Mr. Farran acquired the tools on January
1, 1998. Petitioners did not introduce any receipts to show the
tools’ purchase price or purchase date.
Petitioners have not substantiated that they are entitled to
a depreciation deduction. Further, we are unable to estimate any
amount for depreciation under the Cohan rule because the evidence
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Last modified: November 10, 2007