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of the property, determined under section 1011 for the purpose of
determining gain on the sale or other disposition of the property.
See sec. 167(c).
Mr. Goode testified that the claimed depreciation expense
deduction of $4,139 was calculated with reference to the previous
year’s return, which showed the same or a very similar amount. We
do not have the benefit of the previous year’s return, nor do we
have the benefit of any documentation or testimony that would
establish the adjusted bases of the Robco vehicles or the method
of depreciation used in calculating depreciation with respect to
those vehicles. While we are satisfied that the Robco vehicles
are depreciable property, we cannot find any basis in this record
for determining the amount of the depreciation expense.
Therefore, we will not allow any deduction for depreciation
expense for the Robco vehicles.
Petitioners claimed a $694 insurance expense deduction in
connection with the Robco vehicles. A receipt for insurance
coverage for the period November 2001 through April 2002 shows
that the monthly cost of insurance for the Robco van was $19.16.
The cost of insurance for the Robco pickup truck is not shown on
the November 2001 through April 2002 receipt, but the receipt for
a later period, May 2003 through October 2003, shows the insurance
cost for both the van and the pickup truck. The cost of insuring
the pickup truck was greater than the cost of insuring the van;
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