- 13 - 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 claimed. 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 forPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007