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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.
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