Robert L. and Brenda J. Tarter - Page 13

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         stated that the depreciation was disallowed because petitioners              
         did not provide information to support the deductions and did not            
         establish that the expense was ordinary and necessary.  In                   
         support of the depreciation expense, petitioners offer a one-page            
         depreciation schedule that includes the bases of certain stated              
         assets, the method of depreciation, and the 2001 deprecation                 
              Section 167(a) allows a deduction for a reasonable allowance            
         for the exhaustion, wear and tear, and obsolescence of property              
         used in a trade or business or held for the production of income.            
         The basis on which a depreciation deduction is allowable with                
         respect to any property under section 167(a) is the adjusted                 
         basis 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).                                              
              Petitioners’ depreciation schedule lacks an essential piece             
         of information, the owner of the assets.  For 2001, possible                 
         asset owners include petitioners, BBT, V&E Leasing, B&B Concrete             
         Pumping, or perhaps one of the partners of one of these                      
         partnerships, and it is certainly possible, if not likely, that              
         ownership of the itemized assets changed throughout 2001.                    
         Although we are satisfied that a concrete business would have                
         depreciable assets, we cannot find evidence in the record by                 
         which we can determine the amount of the depreciation expense for            

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