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Memo. 1990-611. The deduction is allowed for the taxable year in
which the property is placed in service. Sec. 179(a). If the
property is used for trade or business as well as other purposes,
the portion of the cost of the property attributable to the trade
or business use is eligible for expensing under section 179 if
more than 50 percent of the property’s use is for trade or
business purposes. See sec. 1.179-1(d)(1), Income Tax Regs.; see
also Whalley v. Commissioner, T.C. Memo. 1996-533.
For 2001, respondent determined that 35 percent of the Astro
Van’s use was for trade or business purposes. Petitioner, in
contrast, contends that the business use was 63.88 percent. To
support her contention, petitioner introduced, inter alia, a
document titled “Weekly Expenses” that includes notations such as
“Vallejo/SF 18th”, “San Leandro 9/22”, and “Riverside 5 - 7th”.
According to petitioner, these notations represent business trips
taken in the Voyager or the Astro Van. The document does not
indicate the distance between petitioner’s home and the
destinations listed, however, nor does it describe the purpose of
the trips. In addition, it is not always clear whether a
particular trip was made in the Voyager or the Astro Van.
We also note that petitioner indicated Riverside,
California, was approximately a 500-mile round trip from her
home. When asked how it was economically feasible to travel that
distance for her cleaning business, petitioner explained that she
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