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photographs or photographs used in petitioner’s advertising dated
before the floating structures were completed.
Petitioner did not provide any evidence showing that the
floating structures were used primarily or at all for business
purposes during the last month of FYE June 30, 1996.35 See
Hobson Motor Co. v. Commissioner, T.C. Memo. 1990-297.
Therefore, this Court also finds petitioner is not entitled to a
depreciation deduction pursuant to section 167(a)(1) for FYE June
1996.
The Court, in reaching its holdings, has considered all
arguments made and concludes that any arguments not mentioned
above are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
35 The lack of adequate documentation also precludes any
deductions for entertainment, amusement, or recreation with
respect to a facility used in connection with such activities.
Sec. 274(d)(2); see Finney v. Commissioner, T.C. Memo. 1980-23.
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Last modified: November 10, 2007