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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
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 for
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