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have claimed $24,750, instead of $14,000, which was the remainder
of the cost of the seven pay phones. However, as the Court found
above, petitioners did not receive the benefits and burdens of
ownership with respect to the seven pay phones. Therefore,
petitioners are not entitled to a depreciation deduction for any
amount under section 167 with respect to the seven pay phones in
2002.
In reaching our holdings herein, we have considered all
arguments made, and, to the extent not mentioned above, we find
them to be moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: March 27, 2008