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.                                                  
          Depreciation Expenses                                                       
               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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