- 19 - Petitioners ask us to agree with their estimate of the values of the improvements and land at the time of purchase. However, they offered only the vaguest estimates of the values of the improvements on the farms. It is not appropriate under Cohan for us to guess the allowable amounts of depreciation. See, e.g., Shaw v. Commissioner, T.C. Memo. 2003-111. We decline to do so. Consequently, we hold that petitioners have failed to substantiate their bases in the buildings. 2. Depreciation of Truck On the 2001 return, petitioners claimed a $7,000 depreciation deduction for the truck, depreciating the $35,000 cost of the truck over 5 years using the straight-line method. On the 2002 return, petitioners attempted to elect to expense $24,000 of the cost of the truck under section 179. On the 2002 return, they deducted the $24,000 expensed amount plus $1,000 of depreciation for the truck. On the 2003 return, petitioners deducted $1,000 of depreciation for the truck. Respondent disallowed all of those deductions. Respondent concedes that the truck was placed in service on January 1, 2001, and was used solely for business purposes. Respondent also concedes that petitioners are entitled to a $7,000 deduction for depreciation of the truck for 2001, 2002, and 2003 but asserts that petitioners may not elect to expense $24,000 of the cost of the truck for 2002.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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